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Mr M received Accelerated Payment Notices (APNs) totalling £125k, payable in June 2015.

Representations were made in June regarding the calculations of the amounts payable, as these had not properly identified the availability of credits to set against the sums demanded by the APNs.

HMRC gave its decision in mid-November, reducing the amount demanded by the APNs to £48k, payable in mid-December. In addition to the reduction in the amount demanded, the client had gained a deferral of six months.

Mr G received Partner Payment Notices (PPNs) charging in excess of £1m, payable in May 2015.

Representations were made against the PPNs, which were successful, HMRC discharging the PPNs. The PPNs were replaced by APNs issued in the same amounts, being payable in November 2015.

Fresh representations were made against the APNs in November, and HMRC gave its decision, confirming the APNs in April 2016, giving a payment date in May 2016, so that twelve months deferral has been obtained.

Judicial Review proceedings challenging the notices are ongoing.

D Limited received PPNs charging in excess of £1m, with payment dates of September 2015.

Representations were made on the basis that the legislation was ineffective to cover D Limited’s particular position.

HMRC agreed, and withdrew the PPNs, so no amount has become payable.

Mrs B received a PPN for £100k with a payment date in November 2015.

Representations were made in November, and HMRC gave its decision upholding the PPN in April 2016, giving a payment date in May 2016, the representations have obtained a six month deferral in the payment date. Mrs B cannot fund full immediate payment, and if not paid, an initial 5% late payment penalty would accrue, with a further 5% after five months late, and a further 5% at 11 months late.

A time to pay arrangement, which spreads the payments over a 12 month period, will ensure that no late payment penalties can arise whilst the agreement is adhered to.


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