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Introduction

Accelerated payment notices (APN) were introduced with effect from 17 July 2014 and allow HMRC to require early payments of disputed tax and / or national insurance contributions (NIC) in relation to certain tax avoidance cases. HMRC can issue APNs to require early payment where those cases are subject to an open enquiry or appeal.

Up until then, HMRC generally allowed disputed tax to be postponed under TMA 1970, s 55, pending the outcome of the enquiry or litigation. This meant that effectively the taxpayer had a low-interest loan from the Government until the case was settled, which could be a number of years.

The rules also reflect Parliament’s approach of using tax policy to influence the behaviour of taxpayers and advisers. Given the need to pay the tax much sooner, it was hoped that the appetite for such avoidance schemes would be reduced.

This guidance note covers the rules which apply to APN that are issued to individuals or companies (including