A7.248B Accelerated payments—penalties and interest
HMRC has the power to issue an accelerated payment notice (APN) to any taxpayer for whom there is an open enquiry, or a matter is under appeal where certain conditions are met1.
The regime applies to income tax, capital gains tax, corporation tax (including amounts chargeable as or treated as corporation tax), the apprenticeship levy, inheritance tax, stamp duty land tax, annual tax on enveloped dwellings (ATED)2
For an overview of the APN provisions, including the conditions that must be met for one to be issued, see A7.248. For a discussion of the APN provisions as they apply to partners in partnership, see A7.248C.
This article discusses the penalties and interest that can be charged when the deadline for payment is missed. For details of the deadline, see A7.248A
Late payment penalties
A late payment penalty is charged where an accelerated payment specified under the APN or partner payment notice (PPN) is paid late3.
Escalating penalties are chargeable at a fixed rate based on the amount of tax unpaid, or still unpaid, at any of three statutory dates4:
• at the