Accelerated Payment Notices (APNs)

Accelerated Payment Notices were brought in by the Government/HMRC as a means of combatting mass tax avoidance. An APN can be issued for either tax or National Insurance.

The number of taxpayers involved in each tax avoidance scheme is not known but it can run into hundreds if not thousands of individual taxpayers. Such taxpayers may be referred to as “participants” of a scheme, essentially the users of the schemes.

Scheme promoters would design a tax avoidance scheme and then mass market the scheme to numerous taxpayers irrespective of their individual tax profile – a case of one size fits all.

If you receive an Accelerated Payment Notice, don’t ignore it and seek specialist advice as a matter of urgency.  The amount demanded is due and there is no right of appeal or postponement.

Follower Notices

HMRC has sought to combat the mass marketing of schemes by identifying a test case. HMRC then seeks to demonstrate that it does not achieve the desired outcome of avoiding tax.

On the basis HMRC wins the test case, thereafter, rather than then taking each user of the scheme through the same process, a Follower Notice is issued to each user or participant in the scheme together with an APN for the tax avoided.  Accelerated Payment Notices are issued on mass by HMRC.

Again, if you receive an APN, don’t ignore it and seek specialist advice as a matter of urgency.  

Help is at hand

Whilst APNs cannot be appealed against nor the tax postponed, there are still steps that can be considered.

If you would like to discuss this matter further, please contact me at paul@pmc.tax or on 07979 313 010.

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