224 Restriction on powers to postpone tax payments pending initial appeal

224  Restriction on powers to postpone tax payments pending initial appeal

(1)     In section 55 of TMA 1970 (recovery of tax not postponed), after subsection (8A) insert—

“(8B)     Subsections (8C) and (8D) apply where a person has been given an accelerated payment notice or partner payment notice under Chapter 3 of Part 4 of the Finance Act 2014 and that notice has not been withdrawn.

(8C)     Nothing in this section enables the postponement of the payment of (as the case may be)—

(a)     the understated tax to which the payment specified in the notice under section 220(2)(b) of that Act relates,

(b)     the disputed tax specified in the notice under section 221(2)(b) of that Act, or

(c)     the understated partner tax to which the payment specified in the notice under paragraph 4(1)(b) of Schedule 32 to that Act relates.

(8D)     Accordingly, if the payment of an amount of tax within subsection (8C)(b) is postponed by virtue of this section immediately before the accelerated payment notice is given, it ceases to be so postponed with effect from the time that notice is given, and the tax is due and payable—

(a)     if no representations were made under section 222 of that

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