APNs apply where avoidance schemes are subject to the Disclosure of Tax Avoidance Schemes (DOTAS) rules or the General Anti-Abuse Rule (GAAR), or where they are similar to a scheme that has already been defeated in the courts.

Once a taxpayer receives an APN, they have 90 days to pay or make representations to HMRC if they consider the notice is incorrect. In July last year the High Court threw out a challenge from 154 users of tax avoidance schemes seeking a judicial review that the regime was unlawful, on the basis it was unreasonable, breached natural justice and represented an abuse of their rights under the European Convention on Human Rights to a fair trial and protection of property.

David Gauke, financial secretary to the Treasury, said: ‘We will not tolerate tax avoidance and Accelerated Payments has been a real game changer.

‘HMRC already wins the vast majority of cases that go to court and now HMRC has taken more than £2bn from tax-avoiders who would have otherwise benefitted from that cash while they were being investigated.

HMRC say it is now issuing over 3,000 APNs a month, and has issued over 41,000 notices since they were first introduced. By the end of 2016, HMRC expects to have completed issuing notices, suggesting it will be close to the total of 64,000 cited last year.

However, last month HMRC revealed it had withdrawn hundreds of APNs which had been incorrectly issued and sent to investors in a particular IR35 scheme run by Montpelier.

Jennie Granger, director general for enforcement and compliance, HMRC, said: ‘Accelerated payments continue to turn the tables on individuals looking to avoid paying their fair share of tax. Those who take part in tax avoidance now have to pay up-front and dispute later. It really is time to get out of avoidance – HMRC wins the vast majority of cases that people litigate, with many more settling before litigation.’