Accelerated Payment Notices are likely to be with us soon for DOTAS registered schemes which are being targeted by the new law introduced in July 2014. Warning letters are already being sent out to those participants that used Contractor Pay Schemes. The demand you will be receiving requires payment of the tax in dispute within 90 days of being issued.
It is very possible that the decision in Philip Boyle v HMRC will be used to issue a Follower Notice for cases that have not been registered under DOTAS and this will tell you to commence ‘corrective action’ to resolve your ‘dispute’ with HMRC. There is no right of appeal but representations can be made in certain circumstances. There are new tax geared penalties for non-compliance. These are some of the measures you should be taking already:
Reviewing your finances with a view to negotiating a time to pay arrangement
Preparing a schedule of monthly incomings and outgoings
Preparing a list of assets at current market value and your liabilities
Preparing a list of your dependents and any other relevant information such as contingent liabilities
Consider raising a lump sum for a payment on account
Progress any loan applications for funds
Consider the realisation of assets and availability of savings
Consider HMRC Certificates of Tax Deposit to reduce accruing interest
Article written by Michael J Perry FCA, Castleham Taxation Services Limited.