The law firm says HMRC has issued more than 79,000 APNs, which require disputed tax to be paid upfront, since their introduction in August 2014, but argues that the high numbers being withdrawn raises questions over whether HMRC is exercising its power with sufficient care.

APNs that have been withdrawn are likely to include cases where simple arithmetical miscalculations can be demonstrated, or where one of the necessary preconditions, which must be satisfied before HMRC can issue an APN, are not satisfied.

Adam Craggs, partner at RPC, said it can be extremely difficult to get HMRC to accept that it has made a mistake in issuing an APN, putting some innocent businesses and individuals under intense financial and emotional stress when faced with what may be incorrect or unlawful tax demands.

RPC is advising that taxpayers should not simply assume an APN is correct – if they feel an APN has been issued incorrectly, they should consider seeking expert legal advice before paying the tax demanded by HMRC.

Craggs said: ‘APNs have always been controversial and these figures are going to do little to silence their critics or reassure taxpayers that HMRC is exercising its powers in a proportionate and lawful manner.

‘Clearly, HMRC doesn’t always get it right so businesses and individuals who feel they’ve been issued with an APN in error should not simply feel they have to accept it and pay up.’

Report by Pat Sweet