While every attempt will be made to ensure that information provided is accurate at the time of publication, it should be treated as guidance only and does not constitute legal or professional advice. Tax law and guidance changes frequently and readers are advised to consult the current relevant publication for the most up-to-date information on this topic.

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Whilst you were working hard in January you may not have noticed that HMRC published a consultation document on accelerating the collection of tax in certain cases where the amount due is disputed. Whilst the majority of the consultation (which includes draft legislation) relates to 'follower cases' (ie open cases which HMRC wishes to close following the successful resolution of a test case in the courts), of much wider interest are the proposals to collect tax from taxpayers who participated in schemes disclosed under the DOTAS rules which are currently under enquiry. As these proposals are expected to be enacted in Finance Act 2014, such taxpayers may only have eight months to review their financial affairs and release the cash to make the payment. Serial participators in avoidance schemes may have a particular problem if cash cannot be released from elsewhere

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