Lee Ellis from the tax litigation department comments in the FT on HMRC’s controversial APN regime

HMRC has withdrawn 3,000 accelerated payment notices (APNs) since introducing them in 2014.

APNs were brought in as part of HMRC’s crackdown on tax avoidance schemes, and require the recipient to pay disputed tax upfront whilst a case is being investigated.

The majority of the APNs that have been recalled have been down to the reclassification of programmes mistakenly included within the Revenue’s disclosure of tax avoidance schemes.

HMRC has explained that a withdrawn APN does not necessarily mean no tax is due, and reiterated that 95% of notices issued have been successful.

Lee Ellis warned that the withdrawal of APNs did not mean HMRC was taking a soft stance on tax avoidance:

“In every substantive case where APNs have been challenged in the courts, HMRC has to date won,” he said. “Thus, those receiving an APN should be under no illusions that it will be difficult to challenge successfully.”

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