Where Revenue successfully challenge certain transactions in a case before the Appeal Commissioners, then Revenue may issue a "payment notice" to the particular taxpayer involved and to any other taxpayer who has claimed a tax advantage as a result of the scheme involved or a substantially similar scheme.
A payment notice may only issue if the scheme:
- Was successfully challenged on the grounds that it was a tax avoidance transaction for the purposes of section 811C Taxes Consolidation Act 1997, or
- Was successfully challenged on the grounds that it failed to comply with a specific anti-avoidance provision ("SAAR") listed in Schedule 33, Taxes Consolidation Act 1997, or
- Was, or should have been, allocated a Transaction Number under the Mandatory Disclosure regime.
This legislation governing payment notices is contained in:
- Chapter 4 of Part 33 Taxes Consolidation Act 1997