Policy paper

Amendment of return to take account of relevant judicial ruling: Follower Notices

Tax Information and Impact Note about the new legislation enabling HM Revenue and Customs to issue a ‘Follower Notice’ in NICs dispute and appeal cases.



The measure will create a new power for HM Revenue and Customs (HMRC) to issue a notice to persons using avoidance schemes that are shown to fail in the courts in another party’s litigation, setting out HMRC’s view that the judicial decision also determines those persons’ cases and that they therefore should settle their cases. If the person decides not to settle in response to this notice they will face a penalty if they are unable to show that their case is materially different from the other party’s litigation.

The measure will take effect 2 months after the National Insurance Contributions Bill 2014 receives Royal Assent. It will be applicable to all cases where there is an NICs dispute or appeal on or after this date, and for which there has been or will be a relevant qualifying judgment.

Published 17 July 2014