Advanced Payment Notices (“APNs”)

We have reported and advised on HMRC’s APNs previously since their introduction two years ago. November saw a number of taxpayers receive APNs or the initial warning letter, in respect of film partnership planning arrangements, following successful court actions by HMRC. It is important on the receipt of APN to take action, otherwise late payment penalties or surcharges becoming due and potential enforcement action being taken to recover the tax. If you can’t pay the tax, then you should contact HMRC immediately to discuss payment options.HMRC are feeling very bullish currently with regards to aggressive tax planning arrangements, having won some many cases, as reported in our October newsletter. 

We have also been notified by one of the main providers via clients who acquired their products, that based on the recent Tax Counsel’s opinions and court decisions, that they are no longer going to defend any HMRC challenges. 

HMRC challenges. Tax avoidance cases outcomes