The most important thing to note about Advanced Payment Notices (APN’s) is that they are issued as a mechanism for HMRC to not have to wait for taxpayers to pay while an appeal is underway. In the event that an appeal succeeds then payments made under an APN are refunded with statutory interest.
By this it should be clear that an APN does not invalidate an appeal it simply means that potential liabilities have to be paid up-front.
LTAG is claiming that for certain repayments made to taxpayers HMRC are out of time to recoup those repayments. If a taxpayer needed to pay an APN the LTAG claim would still be valid.
For those clients that can afford to do so LTAG advises the purchase of Certificates of Deposit so as to mitigate any further interest charges HMRC may choose to make. In effect paying for these CD’s or for an APN has the same immediate cash effect. The only difference being that one, CD’s, is voluntary and the other not.