Follower notices and accelerated payments

What to do if you’ve been involved in a tax avoidance scheme and receive a follower notice or accelerated payment notice from HMRC.


If you’ve been involved in a tax avoidance scheme, you could receive a follower notice, accelerated payment notice (APN), or both from HM Revenue and Customs (HMRC).

The notice you receive will tell you what you need to do. Make sure you follow the steps in the notice, if you don’t, you may have to pay a penalty.

Follower notice

If you use a tax avoidance scheme that has the same or similar arrangements to one that HMRC has successfully challenged in court, HMRC will check your tax affairs and may send you a follower notice.

A follower notice asks you to settle your tax affairs with HMRC. If you don’t, you may have to pay a penalty.

As well as a follower notice, you may also receive an APN. If you do, you’ll need to pay the accelerated payment as well as settling your tax affairs.

Accelerated payment notice

You may receive an APN if there’s an enquiry, dispute or appeal in progress that relates to your tax affairs and you’ve either:

If you receive an APN, you must pay the amount of disputed tax. HMRC will hold this money until the enquiry into your affairs is complete, or your appeal is resolved. You’ll get the money back if HMRC finds you don’t owe it.

If you don’t pay the disputed tax amount by the date on the notice, you may have to pay a penalty.

Partner payment notice

If you’re a member of a partnership you’ll receive a partner payment notice (PPN) instead of an APN.

A PPN usually works the same as an APN, but the individual notice you receive tells you exactly what you need to do.

What to do if you receive a notice

The notice you receive tells you:

  • why it’s been sent to you
  • what you need to do next
  • what to do if you disagree
  • any relevant deadlines
  • the penalties you may have to pay if you don’t take action

You should carry out the actions described in the individual notice you receive.


If you don’t follow the steps described in a notice you receive, you may have to pay a penalty.

If this happens, you’ll receive a notice of penalty assessment telling you how much you have to pay, and by when. It also explains how the penalty is worked out.


You can appeal against any penalties you receive from HMRC relating to follower notices, APNs or PPNs.

You can’t formally appeal against a notice you receive, but it does give you instructions on what to do if you disagree with it.

How to contact HMRC

If you need to contact HMRC to discuss a notice you’ve received, use the contact information at the top of the notice or the letter that comes with it.

Published 9 December 2016