In a recent briefing meeting with HMRC, it was confirmed that members can expect a significant increase in the number of accelerated payment notices (APNs) being issued in the next year. The APN warning comes after the Institute’s NI Tax Committee recently met with the head of HMRC’s High Net Worth Unit (HNWU) in East Kilbride. The East Kilbride unit deals with almost every high net worth (>£20 million) NI taxpayer (see here).

To date HMRC have issued approximately 3,000 notices worth in the region of £1 billion in tax. Initially HMRC’s approach has been to work to deliver a “soft landing” in respect of APNs but the expectation is that 13,000 notices will have issued by next March.

For HNWU cases in which an APN has been issued, the following hints and tips are worth of note:-

• These cases are still managed by the unit;
• The Customer Relationship Manager (CRM) model is still intact;
• The HNWU is keen to work with taxpayers and their agents to resolve issues;
• By withdrawing from such schemes, there is the opportunity to bring the taxpayer’s affairs up to date and achieve a level of certainty over their tax position;
• The HNWU will consider funding/financing issues if these are brought to their attention early in the process. The advice is to speak to the relevant CRM;
• It is essential to tackle difficult conversations early; and
• APNs are akin to a payment on account, it is important to remember that the issue of interest on the underpaid tax will come later as the APNs reflect the underpaid tax only.