Demands from HMRC

Receiving a demand can be a shock whilst dealing with it a daunting process. A tax rebate paid to you some years ago is now demanded back and may no longer exist as liquid funds.  Raising the funds before the short deadline is often unrealistic especially when, in the absence of settled litigation, it can appear that HMRC have little basis for requesting the funds in the first place.

With some demands such as APNs arriving with no formal appeal process, it may appear that investors are left with no option but to pay- this is not your only choice. 

You have three options, they are as follows:


For many, an outstanding HMRC liability will be too concerning. HMRC’s approach is has been largely successful and many investors simply wish to move on. Before doing so it is always advisable to speak with us to ensure the steps you are taking do create the finality you wish. 

If this is your strategy there are a number of considerations:

A time-to-pay arrangement may be necessary or preferred. HMRC have a set of criteria for deciding the extent of time-to-pay. It is important that this process is managed well. Penalties and interest are a risk that an insufficient strategy may give rise to. Contact us for further information on putting this provision in place.

Payment of the demand does not always represent finality. It is simply gifting HMRC the benefit of the tax in dispute. Further litigation and a final position may need to be agreed at a later date.

The only way to reach full resolution is to pursue full settlement. This will involve identifying suitable tax analysis to influence HMRC’s interpretation. Before entering discussions with HMRC it is imperative that a holistic plan is adopted. WTT’s advisers are experienced in achieving suitable settlements and will be happy to discuss with you further. 


Many investors wish to co-operate with HMRC but do not have funds available. Certain strategies afford a delay to the payment process in a co-operative way. WTT offers this service to taxpayers on a success fee-only basis. Contact us for further information.


WTT provides alternative analysis, on a number of schemes, to organised groups of investors. Using this analysis we have been able to reduce liability under the APN by as much as 50%. To see if we are already working on your scheme or have already achieved a reduction please contact our team. 

WTT does not charge for an initial review of your demand. In turn this allows us to analyse the potential routes for achieving your desired outcomes and to detail your options for challenge moving forward.

To date we have successfully achieved a number of demand withdrawals and many reductions. For further information or to speak to one of the team please arrange a callback below.

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