Related Commentary  Related CasesRelated HMRC Manuals

204(1)  HMRC may give a notice (a “follower notice”) to a person (“P”) if Conditions A to D are met.

204(2)  Condition A is that–

(a)a tax enquiry is in progress into a return or claim made by P in relation to a relevant tax, or

(b)P has made a tax appeal (by notifying HMRC or otherwise) in relation to a relevant tax, but that appeal has not yet been–

(i)determined by the tribunal or court to which it is addressed, or

(ii)abandoned or otherwise disposed of.

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