Glossary · UK
What is Accelerated Payment Notice (APN)?
A notice requiring someone under HMRC enquiry into a suspected tax avoidance scheme to pay the disputed tax upfront, before the dispute is resolved.
Full Definition
An Accelerated Payment Notice (APN) is a notice HMRC can issue to a taxpayer who has used arrangements that HMRC believes amount to tax avoidance -- typically because the scheme is similar to one already defeated in the courts, was notifiable under the Disclosure of Tax Avoidance Schemes (DOTAS) rules, or has been counteracted under the General Anti-Abuse Rule -- requiring the disputed tax to be paid within 90 days, even though the underlying enquiry or appeal has not yet been decided. The effect is to remove the cash-flow advantage of avoidance: instead of holding onto the disputed tax until a tribunal rules on the scheme, the taxpayer must hand it over to HMRC upfront, with the money refunded (with interest) only if they are later proved right. APNs were introduced by the Finance Act 2014 specifically to tackle mass-marketed avoidance schemes, where large numbers of people had used the same or very similar arrangements and enquiries could otherwise drag on for years while participants kept the tax they disputed. There is no general right of appeal against an APN itself -- a recipient can only challenge it on narrow procedural grounds, such as that the statutory conditions for issuing it were not met -- although the underlying tax dispute can still be argued through the normal enquiry and tribunal process. Failure to pay within the deadline triggers a penalty regime, starting at 5% of the unpaid amount and rising if the debt remains outstanding.