R (Haworth) v HMRC [2018] WTLR 459

Wills & Trusts Law Reports | Summer 2018 #172

On an application for judicial review, the claimant challenged the decisions of HMRC to issue him with a follower notice and an accelerated payment notice in relation to gains arising to the Trustees of a settlement (‘the Trust’) from the disposal of assets. The claimant was the settlor and, along with his family, a beneficiary of the Trust. The notices were issued under Part 4 of the Finance Act 2014.


A follower notice can be given where the principles laid down or reasoning given in a final judicial ruling would, if applied to the taxpayer’s chosen arrangements, deny h...