HMRC may have to repay tens of millions in Follower Notice penalties issued to taxpayers, after a key decision in the Supreme Court last month cast doubt on their legitimacy. In response to a freedom of information request by law firm Fieldfisher, HMRC confirmed 1,330 Follower Notice Penalties totalling around £45m have been issued by HMRC since the Follower Notice regime was introduced in 2014. The Supreme Court decision (R (Haworth) v Revenue and Customs Comrs [2021] UKSC 25), handed down on 2 July 2021, called into question the authority of all Follower Notices issued by HMRC to ta...
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