HMRC wins £200k case over accelerated payment notices

The court has ruled in favour of HMRC upholding payment notices totalling over £200,000 in a lead case that will affect hundreds of taxpayers 

The First Tier Tribunal has dismissed the appeals against the accelerated payment notices (APN) and late payment penalties totalling £200,769.56 from Exclusive Promotions Limited and Mark Fox after the companies used avoidance schemes to evade PAYE tax and National Insurance contributions (NICs).

Exclusive Promotions entered into a tax planning arrangement known as the Partly Paid Share Scheme whilst Fox entered two other arrangements known as ‘Penfolds’ and ‘Hamilton’.

The case is significant as the two appellants are represented by Reynolds Porter Chamberlain LLP which represents around 500 other appellants in a similar situation. The case will be used for relevant guidance for the rulings in the other cases.

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