Accelerated payment notices

By Tolley
Accelerated payment notices

The following Personal Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Accelerated payment notices
  • Introduction
  • Summary
  • Scope of the accelerated payment rules
  • Penalties
  • Collection proceedings
  • What if the taxpayer subsequently loses the appeal?
  • What if the taxpayer subsequently wins the appeal?
  • Use of APNs by HMRC


Parliament introduced rules with effect from 17 July 2014 which 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 accelerated payment notices (APNs) to require early payment where those cases are subject to an open enquiry or appeal.

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 APNs which are issued to individuals. It does not cover APNs issued to partners and partnerships, known as partner payment notices (PPNs). The procedure for PPNs is slightly different, see section 2.16 of the HMRC guidance  and Simon’s Taxes A7.248C.

For details of how APNs can apply to group relief claims by companies, see Chapter 5 of the HMRC guidance  and Simon’s Taxes A7.248D.


HMRC can require accelerated tax payments via an APN where the tax arrangement producing the tax advantage is under enquiry or appeal and either:

  • the chosen arrangements are notifiable under the DOTAS rules and have been notified
  • HMRC has given a follower notice in relation to the same matter, or
  • a GAAR counteraction notice has been given in relation to the same tax advantage

The taxpayer has 90 days from the date

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