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No accelerated payment notices (APNs) were issued in 2020-21 according to information obtained by law firm RPC. This is the first year that none have been issued since the regime was introduced in 2014.
Some have accused HMRC of being heavy-handed in its use of APNs in the past. Indeed of the 81 540 that have been issued since 2014 12% have since been withdrawn. In many cases this was due to HMRC not meeting the necessary conditions for issuing them. For each of the past three years HMRC has withdrawn more APNs than it has issued.
Partner and head of the tax disputes team at RPC Adam Craggs said: ‘After issuing a large number of APNs in the early years following their introduction HMRC appears to be quietly winding down this programme.’
He added that the negative media attention given to APNs and the loan charge may...
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