HMRC collects over £4bn from APNs

More than £4bn has been collected through accelerated payment notices (APNs) under the ‘pay now, dispute later’ rules for people who have used a tax avoidance scheme, according to HMRC

HMRC says it has now issued APNs on all the schemes that were already under investigation when the new rules were introduced in 2014, with over 75,000 APNs issued in total.

According to HMRC analysis, the average bill for large companies seeking to avoid tax is £6m, while for individuals and small corporates it is £74,000.

David Richardson, director general for customer compliance group in HMRC, said: ‘APNs have helped level the playing field by changing the economics of avoidance.’

APNs apply where avoidance schemes are subject to the disclosure of tax avoidance schemes (DOTAS) rules or the general anti-abuse rule, or where they are similar to a scheme that is already been defeated in the courts.

Taxpayers have 90 days after receiving the notice to pay or make representations to HMRC if they consider it is incorrect. HMRC says it upholds 90% of decisions.  If a taxpayer has used a scheme that is the same as or very similar to a scheme that HMRC has defeated in court, HMRC can issue a follower notice (FN) requesting settlement.  

HMRC currently has more than 600 schemes and 80,000 users under investigation. The tax authority says it wins around eight out of ten cases taken to court, with many more settling before litigation. The latest decision of the High Court was R (oao Dickinson & Others) v HMRC, handed down on 7 July 2017.

Richardson said: ‘We are pleased that the High Court has again supported HMRC’s operation of the Accelerated Payments regime. This is our sixth win out of six judicial reviews of APNs.’

HMRC has also reported that supply and demand for tax avoidance schemes is falling. The number of new schemes notified in 2015-16 under the DOTAS regime fell by 99% on 2005-06, from 600 to seven. 

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