Accelerated Payment Notices (“APNs”) are notices typically arising because HMRC considers that the taxpayer has been involved in a tax avoidance scheme. HMRC may issue an APN under Section 219 of the Finance Act 2014.
HMRC will typically be aware of this because of the requirement under the Disclosure of Tax Avoidance Schemes (DOTAS) regulations. APNs require the recipient to pay the amount of wrongfully avoided tax stated in the notice to HMRC within 90 days of its receipt.
Accelerated Payment Notices can be issued where the recipient has been involved in a tax avoidance scheme disclosed under the Disclosure of Tax Avoidance Schemes (DOTAS) rules, caught by the General Anti Abuse Rule (GAAR) or has received a Follower Notice arising from their participation in the scheme.
They commonly arise in such schemes as Employee Benefit Trusts.
APNs can be issued if there is an open tax enquiry or a claim submitted by the taxpayer, or an open appeal relating to the same. Secondly, the underlying feature presumed to be the case by HMRC is that the taxpayer will have received some form of a tax advantage from the scheme.
HMRC can issue an APN if they have issued a Follower Notice in relation to a specific tax avoidance scheme or similar avoidance scheme. Follower Notices are issued when HMRC has obtained a court ruling that it considers will also apply to the same or similar tax avoidance schemes entered into by that taxpayer. If a person receives a Follower Notice but does not settle the liability in response to the Follower Notice, they may face a penalty of up to 50% of the tax in dispute.
There is no specific right to appeal an Accelerated Payment Notice but you can make representations nevertheless under Section 222 of the Finance Act 2014. You cannot negotiate with HMRC on the amount required by the Accelerated Payment Notice, nor will they often be flexible about the 90 day time period for payment.
If you make representations the payment period might be increased but it is not something to be relied upon as it will clearly depend upon the merits of the representations. You can make representations on a small number of grounds. These grounds are: either that the conditions required for the issue of an APN have not been met or that the amount specified is incorrect. You must make representations within 90 days and HMRC has a duty to consider the representations and let you know its decision on the position of the APN in response.
You have to make representations to an Accelerated Payment Notice before you will know if it is a worthwhile exercise. Obviously, it is recommended that you seek independent advice so that the representations you make are accurate and productive.
It is worth however noting that such representations about an APN may face an uphill struggle due to some mistake that is of limited significance. Section 114(1) of the Taxes Management Act 1970 says:
An assessment or determination, warrant or other proceeding which purports to be made in pursuance of any provision of the Taxes Acts shall not be quashed, or deemed to be void or voidable, for want of form, or be affected by reason of a mistake, defect or omission therein, if the same is in substance and effect in conformity with or according to the intent and meaning of the Taxes Acts, and if the person or property charged or intended to be charged or affected thereby is designated therein according to common intent and understanding.
At Oliver Elliot, we can help you make these representations so call us now on 020 3925 3613 and speak to our CEO, Elliot Green, who has a wealth of experience in dealing with APNs and importantly with HMRC.
It is worth remembering that the tax regime is governed by self assessment. Therefore because you the taxpayer self assesses the amount of tax you have to pay, HMRC relies upon those figures to understand your tax affairs. You may find if your tax compliance is incomplete, as a result the Accelerated Payment Notice you receive could be incorrect.
At Oliver Elliot, our CEO, Elliot Green, has made representations concerning APNs and this has led to reductions in HMRC tax debts.
It is therefore important that if you have any concerns about the amount stipulated in the Accelerated Payment Notice that you ensure representations are made within the 90 days.
Whether your representations are successful or otherwise, you will have 30 days from the date of HMRC’s response to your representations to pay the relevant amount in question.
As Accelerated Payment Notices are generally used where the taxpayer has used a tax avoidance scheme to avoid paying the full amount of tax, in most situations, you will know if you are likely to be affected.
You will usually be informed as to your forthcoming Accelerated Payment Notice, either through the receipt of a Follower Notice, or a letter that HMRC typically sends in advance of the issue of the APN. This will tell you that you will be receiving one and provide further information about the process.
You should not be personally liable for an Accelerated Payment Notice; it is not a Personal Liability Notice or a Joint Liability Notice.
A Personal Liability Notice is a notice from HMRC arising due to fraud or neglect. In other words, it indicates that HMRC has serious concerns about the conduct of the taxpayer and can pass a liability from the company to a relevant Director. A similar standard of potential misconduct is likely to typically apply to a Joint Liability Notice.
An Accelerated Payment Notice has not even determined with finality who owes the tax. It is a matter still to be resolved. Fraud and neglect is an entirely different position to tax avoidance which might involve a scheme that HMRC may not approve of but it can still be perfectly lawful.
You have 90 days to pay the amount referred to on the APN, unless you make representations. If you make representations thatn you may be given longer to pay.
If you ignore an Accelerated Payment Notice you could be charged penalties for late payment and enforcement action taken by HMRC to collect in the monies claimed.
If you cannot pay an Accelerated Payment Notice then you should contact HMRC as soon as possible to discuss your options towards the settlement of the amount claimed on the APN.
Yes you can. You could receive multiple APNs. Accelerated Payment Notices are sent out for each year of the avoidance scheme you are in and for each type of tax involved.
Not necessarily. An Accelerated Payment Notice covers the tax or NIC relating to a specific avoidance scheme covered by the APN. Furthermore, the amount shown might well not be the final liability applicable. You should be particularly aware that an APN will usually not include any interest, penalties or other tax that may be due in the relevant tax year. Therefore there can be additional amounts to pay.
You can make representations against an APN and the tax or NIC disputed within the same.
If you consider that the amount referred to in the Accelerated Payment Notice is wrong or that HMRC have wrongly issued it then you can make representations and HMRC will consider the same. Representations should be made in writing to the address shown on the APN, within the 90 days before payment becomes due. If you make representations, HMRC will respond to you setting out their review. The response to your representation will tell you what you need to do next.
The reason is that a settlement offer is not the same thing as the Accelerated Payment Notice. Furthermore, a settlement offer from HMRC is likely to incorporate interest an penalties. For those reasons, the figures can be different.
Yes you can. If you want to finalise your tax affairs and you have received an Accelerated Payment Notice, you should get in touch and contact HMRC as soon as possible. You still have to pay the APN by the due date and this will enable you to avoid late payment penalties. However, any payment received will be treated as a payment on account of your final tax liability and will stop the interest building up on the debt from the date.
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We can explore your situation and consider the best way to help you and your business needs. You can call us 020 3925 3613 or fill in the form below and will get back to you quickly. We Know Insolvency Inside Out.
Author: Elliot Green
Last Updated: August 17, 2026
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This page is not legal advice and is not to be relied upon as such. This article What Is An HMRC Accelerated Payment Notice? is provided for information purposes only. You should take independent advice on the facts of your case. No liability is accepted for reliance upon this post.
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