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<p>The Accelerated Payment regime is designed to change the underlying economics of
tax avoidance by requiring disputed tax to be paid upfront while an avoidance scheme
is investigated. HMRC can only issue Accelerated Payment Notices (APNs) in tightly
defined circumstances, set out in legislation.</p><p> </p><p>The 2019 Loan Charge
is a tax charge which applies to disguised remuneration (DR) loan balances which remained
outstanding at 5 April 2019. APNs and the 2019 Loan Charge are two separate, distinct
regimes. HMRC cannot issue APNs in relation to the Loan Charge.</p><p> </p><p>There
is no estimate on how many people will be made bankrupt as a result of APNs issued
in connection with avoidance schemes that seek to disguise remuneration. HMRC do not
want to make anybody bankrupt, and insolvency is only ever considered as a last resort.
HMRC will work with individuals to reach sustainable and manageable payment plans
wherever possible.</p><p> </p>
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