Accelerated Payments Notices

An Accelerated Payment Notice (APN) is a notice issued by HMRC to pay sums due in respect of tax or National Insurance Contributions. These notices are issued to persons who have received a Follower Notice in relation to an avoidance scheme, or those involved in avoidance schemes disclosed under the Disclosure of Tax Avoidance Schemes (DOTAS) rules, or under the General Anti-Abuse Rules. The APN notice ensures that disputed tax or National Insurance Contributions are submitted upfront, ahead of court case deciding on the permissibility of a tax scheme, thus removing the cash flow benefit from users of tax avoidance schemes over the majority of taxpayers who pay their contributions upfront. Penalties will incur if there is a failure to pay the accelerated payment within ninety days of the notice. There is no right of appeal against such a notice, however, you can send written representations within ninety days of receiving the notice to object, but only on the grounds that the conditions of the notice were not fulfilled.

Bright Line Law provides specialist advisory, advocacy, litigation, policy and strategic services. Bright Line Law is highly regarded as a specialist provider, winning the Financial Times Innovative Lawyers of 2017 award, as well as being Top Ranked within the UK Bar Chambers for 2018 and 2019. If you require specialist advice on tax, contact our team or telephone us on + 44 (0)203 709 9470.

Jonathan Fisher QC
Lead Counsel

Email jf@brightlinelaw.co.uk
Telephone + 020 3872 2852

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