Part 1 Amendment of Chapter 2 of Part 4 of FA 2014
Finance Act 2021 (2021 c 26) | Legislation

SCHEDULE 28 Follower Notice Penalties

Section 119

Part 1 Amendment of Chapter 2 of Part 4 of FA 2014

1

Chapter 2 of Part 4 of FA 2014 (follower notices) is amended as follows.

Additional penalty for unreasonable tax appeal

2

After section 208 (penalty if corrective action not taken in response to follower notice) insert—

“208A Additional penalty for unreasonable tax appeal

(1)     In the case of a follower notice given by virtue of section 204(2)(a) in relation to a tax enquiry into a return or claim made by P, this section applies where—

(a)     P makes a tax appeal addressed to the tribunal in relation to the return or claim, and

(b)     P is assessed to a penalty under section 208.

(2)     In the case of a follower notice given by virtue of section 204(2)(b) in relation to a tax appeal made by P, this section applies where—

(a)     the tax appeal is addressed to the tribunal, and

(b)     P is assessed to a penalty under section 208.

(3)     P is liable to pay a penalty (in addition to the penalty under section 208) if P or P's representative is found to have acted unreasonably

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