225 Protection of the revenue pending further appeals

225  Protection of the revenue pending further appeals

(1)     In section 56 of TMA 1970 (payment of tax where there is a further appeal), after subsection (3) insert—

“(4)     Subsection (5) applies where—

(a)     an accelerated payment notice or partner payment notice has been given to a party to the appeal under Chapter 3 of Part 4 of the Finance Act 2014 (and not withdrawn), and

(b)     the assessment has effect, or partly has effect, to counteract the whole or part of the asserted advantage (within the meaning of section 219(3) of that Act) by reason of which the notice was given.

(5)     If, on the application of HMRC, the relevant court or tribunal considers it necessary for the protection of the revenue, it may direct that subsection (2) does not apply so far as the tax relates

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