HomeFWJ TakeawayTax disputesDisguised remuneration and APNsAccelerated payment notices guidance

An accelerated payment notice is a notice provided by HMRC to the taxpayer to remit the disputed Income Tax and National Insurance in the amount attributable to the net benefit whilst the tax dispute continues.

It is commonly sent as an alternative (or in addition to) a follower notice where the case, in principle at least, has similar circumstances and has been separately decided in court.

  • whilst an accelerated payment notice is an out of court procedure, and accordingly there are no formal routes to appeal, early warning of the intended payment sought will be made by HMRC and there will be an opportunity for representations to be provided in a similar fashion to the approach taken by HMRC in respect of personal liability notices;
  • the accelerated payment notice is often used where disclosure has not been made via the DOTAs process, as early disclosure to HMRC is encouraged.

There are a number of legal cases which impact on the legitimacy of an accelerated payment notice, including circumstances of judicial review, the form and content and whether actual payment can be injuncted whilst such reviews are ongoing.

At Francis Wilks & Jones we have considerable experience of negotiations with HMRC, including Accelerated Payment Notices, Personal Liability Notices, VAT security or any other claim – including appeals to tax tribunals or insolvency claims by liquidators and defending director disqualification claims. Call one of our team today and we can help.

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