HMRC issues enforcement actions against unpaid APNs

HMRC has begun cracking down on unpaid accelerated payment notices (APNs), issuing a first round of ‘enforcement actions’ against 14 taxpayers who have failed to meet terms and pay disputed tax within 90 days, according to Moore Stephens

The firm says it obtained the figures via a freedom of information request, and points out that the sums involved can be sufficient to see a business or individual facing possible insolvency or bankruptcy.

APNs are issued when HMRC suspects individuals or businesses of using a tax avoidance scheme and require an upfront payment of the full amount of disputed tax within 90 days, prior to any hearing and without the right to appeal.

Moore Stephens says that HMRC has issued more than 60,000 APNs since being introduced in July 2014 and collected more than £3bn through the new tool.

Dominic Arnold, head of tax investigations and disputes at Moore Stephens, said: ‘It looks like the phoney war is over – we expect the trickle of APN enforcement actions to gather pace.

‘APNs will not disappear. Businesses and individuals who face an APN are running out of time to decide whether to challenge their APN or reach a settlement with HMRC. Ignoring them, in the hope they will go away, will only result in higher eventual penalties.’

Previous research has suggested that one in 14 APNs has been issued in error by HMRC, with Moore Stephens advising individuals to take expert advice before paying what can be substantial sums.

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