Legislation will be introduced in 2015 to allow HMRC to recover tax and tax credit debts of £1,000 or more directly from taxpayer accounts. We are invited to take comfort that the exercise of this power will be subject to rigorous safeguards! Of more immediate concern to clients (who may have already spent savings achieved from historic tax schemes) is that legislation will be introduced in 2014 to enable HMRC to issue a Notice to Pay to any taxpayer who is subject to an open enquiry, or when the matter is under appeal where HMRC are asserting that a tax advantage has arisen by the use of arrangements under the Disclosure of Tax Avoidance Schemes (DOTAS) rules.
The notice will require the taxpayer to pay the tax in dispute within 90 days. We may see a flurry of Voluntary Arrangements as clients require more time to convert fixed assets into cash. As always, we would be happy to advise clients who fall foul of this change in legislation.
If you or any of your clients have any concerns about the implications of these changes please call Paul Bailey or Tom Ahmad on 020 8662 6070.