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Warning given to recipients of Accelerated Payment Notices (APNs)

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Updated: 5th February 2020

HMRC Payment Notice Recipients Urged to 'Consider Their Validity' Before Taking Action

Anyone who finds themselves in receipt of either an accelerated payment notice (APN) or a partner payment notice (PPN) from HM Revenue & Customs (HMRC) should consider the validity of the associated demands before making payments.

That’s according to the professional services firm PwC, which has issued its advice as a general warning to APN and PPN recipients after it emerged that HMRC has backtracked on its stance in a number of cases involving these notices.

HMRC has stepped up its use of payment notices in recent months as a means of demanding payment of tax amounts that it deems to be due from specific individuals.

However, it has emerged in recent days that the government’s main tax-gathering body may have issued APNs and PPNs without having fully ensured that each case merited the use of payment notices.  

The result of which revelation has been that thousands of people who had no choice but to make payments to HMRC in response to APNs or PPNs could now be in line to receive repayments of those amounts from the UK’s tax authorities.

According to some experts, the apparent lack of certainty around whether or not HMRC has been using its payment notice mechanisms properly has cast a shadow of doubt across the entire process.

“Individuals who are issued with an APN or PPN should carefully consider their validity, prior to making representations or paying the disputed amount,” a recent statement from PwC on the subject recommends.

The same firm has suggested that APN or PPN recipients should seek to represent themselves as robustly as possible in communication with HMRC in the context of any associated disputes.

HMRC is understood to have been forced to accept that it has not always met its statutory requirements in relation to the issuing of payment notices and some notices have now been withdrawn because relevant procedures are known not to have been followed.

APNs and PPNs effectively give their recipients 90 days to pay any amounts being demanded, which has meant that these notices have emerged as a common source of frustration and cash flow concern for hundreds of business men and women around the UK.