The tax demand is as a result of the new powers granted to HMRC in the 2014 Finance Act, enabling it to crackdown on tax avoidance schemes.
Simon Newsham tax partner in Winckworth Sherwood is quoted in the International Business Times:
"This is the most significant of the many clampdowns by HMRC on those taxpayers that have engaged in tax avoidance schemes and practices.
HMRC is looking to recoup £5.1BN over the current tax year and by the end of 2015/16.
Individuals will be naturally concerned when they receive these demands and it is entirely possible that they will not be able to afford to pay straightaway.
Their first call should be to the scheme promoter, presuming they are still in existence, who will be able to advise on whether they continue to challenge HMRC's interpretation of the scheme.
If the promoter accepts HMRC's interpretation, investors should then seek advice from a tax professional before engaging with HMRC."
Accelerated Payment Notices are issued where a taxpayer has entered into a tax avoidance arrangement that has been notified to HMRC under the disclosure of tax avoidance scheme rules (DOTAS) or where a counteraction has taken place under the general anti-avoidance rules (GAAR).
Taxpayers who receive an Accelerated Payment Notice will have to pay the tax due to HMRC within 90 days.
By January 2015, HMRC will be issuing 2,500 Accelerated Payment notices per month and it is on track to deliver notices to 43,000 tax avoidance scheme users, covering £7.1BN of disputed tax, by the end of March 2016.
Jennie Granger, Director General of Enforcement and Compliance, HMRC, said:
"HMRC is making good progress in tackling marketed avoidance as today's figures illustrate. If anyone is concerned about being able to pay the notice they should contact us as soon as possible to discuss their options."
Tax does have to be taxing.
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