← Back to imported archive search
The number of APN's related to and not related to DR Schemes
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: HM Revenue and Customs
did not have
the information requested.
Imported path: /opt/loancharge/imports/wdtk/requests/the_number_of_apns_related_to_an
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/the_number_of_apns_related_to_an
TITLE: The number of APN's related to and not related to DR Schemes
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: HM Revenue and Customs
did not have
the information requested.
REQUEST_SLUG: the_number_of_apns_related_to_an
CAPTURED_AT: 2026-05-19T07:16:06+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T13:00:44", "first_seen_page": "1", "first_query_term": "\"disguised remuneration\"", "first_date_after": "2022/01/01", "first_date_before": "2023/01/01", "matched_query_terms": "\"disguised remuneration\"", "matched_date_ranges": "2022/01/01 to 2023/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22disguised%20remuneration%22/requests?commit=Filter&query=%22disguised+remuneration%22&request_date_after=2022%2F01%2F01&request_date_before=2023%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}
ATTACHMENTS:
- FOI2022_00028.pdf | https://www.whatdotheyknow.com/request/the_number_of_apns_related_to_an/response/1980166/attach/3/FOI2022%2000028.pdf?cookie_passthrough=1 | application/pdf | 115125 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_number_of_apns_related_to_an/response/1980166/attach/html/3/FOI2022%2000028.pdf.html | | 0 bytes
- IR2022_08116.pdf | https://www.whatdotheyknow.com/request/the_number_of_apns_related_to_an/response/2014503/attach/3/IR2022%2008116.pdf?cookie_passthrough=1 | application/pdf | 212264 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_number_of_apns_related_to_an/response/2014503/attach/html/3/IR2022%2008116.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: Trevor Price
5 January 2022
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Regarding Accelerated Payment Notice known as APN please can you let me know the following information:
1) The total number of individuals who are deemed to have entered in to Disguised Remuneration schemes who have received APNs.
2) The total number of individuals who are NOT deemed to have entered in to Disguised Remuneration schemes who have received APNs.
3) For each of the groups of individuals in 1) and 2) the number of APNs closed as a result of the individual settling by group of individuals 1) and 2).
Yours faithfully,
Trevor Price
================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
6 January 2022
--------------------------------------------------------------------------------
Our ref: FOI2022/00028
Dear Mr Price,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 5 January.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our obligations under Freedom of Information Act or, if we think it's
an enquiry that we don't need to address under the terms of the Act, let
you know why. If it is the latter we will, if possible, pass it on to a
more appropriate part of the Department for answer.
While we aim to re spond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team
================================================================================
MESSAGE 3 [outgoing]
HEADER: Trevor Price
8 February 2022
Delivered
--------------------------------------------------------------------------------
Dear FOI Central Team,
I would like to remind you that is FOI request was submitted on 5th Jan 2022, by law the authority should had responded promptly and by 2nd Feb 2022. Please reply with the information I requested promptly.
Yours sincerely,
Trevor Price
================================================================================
MESSAGE 4 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
22 February 2022
--------------------------------------------------------------------------------
1 Attachment
FOI2022 00028.pdf
112K
View
Download
Dear Mr Price ,
We are writing in response to your request for information, received on 5
January 2022.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
MESSAGE 5 [outgoing]
HEADER: Trevor Price
24 February 2022
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of HM Revenue and Customs's handling of my FOI request 'The number of APN's related to and not related to DR Schemes'.
Your reply states the following:
"The Counter-Avoidance case management system (which records the number of accelerated payments) is currently undergoing essential maintenance and improvements, which means we are currently unable to evaluate the data on that system to provide the breakdown you have requested. We started the maintenance works in January 2022, and currently expect that they will take around four months to complete. We therefore advise that you make a new request then"
From the above I am assuming that the Counter-avoidance case management system will not be available "currently" for 4 months from the date of your reply until about May/June 2022.
As I have worked in I.T for many years, I find the above both strange and shocking, I would had thought
that the current live release of the "CA case management system" would still be available, while changes to improve the system are being developed and tested. Normally when changing I.T systems a plan is put in place to keep the current system up and running, while a scheduled date is agreed for the cut-over to the improved system. Questions (1) Does this plan exist? (2) is it possible to have sight of this plan?
Its shocking that a government department such as HMRC cannot give me simple figures about the amount / count of APNs. I also find it shocking that such an important system will not be available to answer CA case enquires from citizens, taxpayers and their tax advisers until May/June 2022. As it will impact their cases and impose further interest and penalties, through no fault of their own, while the system is down. Question: (3) What alternative / backup plans have been put in to place to avoid this situation?
Therefore I would of thought its in the public interests for citizens, taxpayes and tax advisors to know about this outage, so alternative arrangements could be made. Question: (4) Has this outage not been made public? (5) if not why not?
With reference to page 5 of this ICO guidance re timescales you must have known you could not respond within the 20 days, therefore you should have told me within 20 working days, Question: (6) why did you take so long?
Therefore saying the system is under maintenance seems to be delaying tactic to stop the release of the APN information I requested (7) Why is that?
A full history of my FOI request and all correspondence is available on the Internet at this address:
https://www.whatdotheyknow.com/request/t...
Yours faithfully,
Trevor Price
================================================================================
MESSAGE 6 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
25 February 2022
--------------------------------------------------------------------------------
Our ref: IR2022/08116
Dear Mr Price,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 24 February.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our obligations under Freedom of Information Act or, if we think it's
an enquiry that we don't need to address under the terms of the Act, let
you know why. If it is the latter we will, if possible, pass it on to a
more appropriate part of the Department for answer.
While we aim to r espond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team
================================================================================
MESSAGE 7 [incoming]
HEADER: Team, FOI,
HM Revenue and Customs
5 April 2022
--------------------------------------------------------------------------------
1 Attachment
IR2022 08116.pdf
207K
View
Download
Dear Mr Price,
We are writing in response to your request for information, received 24
February.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
--------------------------------------------------------------------------------
ATTACHMENT: FOI2022_00028.pdf
TEXT_FILE: FOI2022_00028.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’.
Text Relay service prefix number – 18001
OFFICIAL
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Trevor Price
By email: request-820159-
889036c2@whatdotheyknow.com
Email
foi.request@hmrc.gov.uk
Web
www.gov.uk
Date: 22 February 2022
Our ref:
FOI2022/00028
Dear Mr Price
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 5 January, for the following information:
“Regarding Accelerated Payment Notice known as APN please can you let me know the
following information:
1) The total number of individuals who are deemed to have entered in to Disguised
Remuneration schemes who have received APNs.
2) The total number of individuals who are NOT deemed to have entered in to Disguised
Remuneration schemes who have received APNs.
3) For each of the groups of individuals in 1) and 2) the number of APNs closed as a result
of the individual settling by group of individuals 1) and 2).”
Our response
Please accept our apologies for the delay in replying to your request for information.
We have interpreted your request as seeking information for the total number of disguised
remuneration related APNs and the total number of non-disguised remuneration related
APNs issued to and settled by individuals.
The Counter-Avoidance case management system (which records the number of
accelerated payments) is currently undergoing essential maintenance and improvements,
which means we are currently unable to evaluate the data on that system to provide the
breakdown you have requested. We started the maintenance works in January 2022, and
currently expect that they will take around four months to complete. We therefore advise
that you make a new request then.
If you are not satisfied with our reply, you may request a review within 40 working days of
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the
top.
If you are not content with the outcome of an internal review you can complain to the
Information Commissioner’s Office.
--- PDF page 2 ---
2
OFFICIAL
Yours sincerely,
HM Revenue and Customs
--------------------------------------------------------------------------------
ATTACHMENT: IR2022_08116.pdf
TEXT_FILE: IR2022_08116.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 3
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’.
Text Relay service prefix number – 18001
OFFICIAL
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Trevor Price
By email: request-820159-
889036c2@whatdotheyknow.com
Email
foi.request@hmrc.gov.uk
Web
www.gov.uk
Date: 5 April 2022
Our ref:
IR2022/08116
Dear Mr Price
Freedom of Information Act 2000 (FOIA)
Thank you for your email of 24 February, which seeks a review of our original response to
your information request.
Original request
On 05 January 2022, you asked for the following information:
1) The total number of individuals who are deemed to have entered in to Disguised
Remuneration schemes who have received APNs;
2) The total number of individuals who are NOT deemed to have entered in to Disguised
Remuneration schemes who have received APNs; and
3) For each of the groups of individuals in 1) and 2) the number of APNs closed as a
result of the individual settling by group of individuals 1) and 2).
Our response
We replied on 22 February 2022 explaining that the case management system recording the
number of APNs was undergoing some maintenance and improvements. We explained that
the works were started in January 2022 and were expected to take four months to complete
and unfortunately during that time we would be unable to evaluate the data you requested.
Internal review request
On 24 February you asked us to review our handling of your request:
“I am writing to request an internal review of HM Revenue and Customs' handling of my FOI
request 'The number of APN's related to and not related to DR Schemes'.”
You then state, that “From [our response] I am assuming that the Counter-Avoidance case
management system will not be available "currently" for four months from the date of your
reply until about May/June 2022…
…Normally when changing I.T systems a plan is put in place to keep the current system up
and running, while a scheduled date is agreed for the cut-over to the improved system.
Questions (1) Does this plan exist? (2) is it possible to have sight of this plan?...
--- PDF page 2 ---
2
OFFICIAL
….I also find it shocking that such an important system will not be available to answer CA
case enquires from citizens, taxpayers and their tax advisers until May/June 2022. As it will
impact their cases and impose further interest and penalties… (3) What alternative /
backup plans have been put in to place to avoid this situation?
…it is in the public interests for citizens, taxpayers, and tax advisors to know about this
outage, so alternative arrangements could be made. Question: (4) Has this outage not
been made public? (5) if not why not?
With reference to page 5 of this ICO guidance re timescales you must have known you could
not respond within the 20 days, therefore you should have told me within 20 working days,
Question: (6) why did you take so long?
Therefore saying the system is under maintenance seems to be delaying tactic to stop the
release of the APN information I requested (7) Why is that?”
Internal review
The purpose of this review is to assess how your request was handled and to determine
whether the original decision given to you was correct.
We received your request on 05 January 2022 and replied by email on 22 February 2022. We
acknowledged that was outside of the statutory deadline outlined in section 10(1) of the FOIA
and apologised for the delay.
The response also set out our review procedure and your right to complain to the Information
Commissioner, as required by section 17(7) of the FOIA.
Considerations
The response to your initial request stated that the case management system upon which the
department records Accelerated Payment Notices (APNs) was undergoing improvement and
maintenance works that began in January 2022 and it was expected to take four months to
complete. It also stated, that during that time we would be unable to extrapolate the different
data sets you have requested.
Towards the end of 2021, there was some uncertainty over some of the figures recorded on
the system. Following a review, it was agreed that part of the system needed to undergo
maintenance to correct this.
The purpose of the maintenance is solely to ensure that that part of the system that records
the APNs is working optimally and reflects the correct number of records. This part of the
system is an internal tool that is used for our own data analysis. It therefore does not affect
customer files, their tax affairs, or HMRC’s ability to deliver quality customer service. We are
still able to receive payments, reallocate payments to outstanding or settled liabilities, and
issue repayments to customers. These works will not create any additional burdens for
customers in respect of interest or penalties. We therefore had no reason to announce that
this part of the system will be down temporarily and no need for a back-up plan to handle
customers.
I note that the original response also states, that ‘improvement…works’ are underway (in
addition to maintenance works), but I should clarify that no specific improvements (i.e. system
changes) are being made to the case management system, it is solely maintenance works.
We therefore have no need for a schedule or plan for switching to a new/improved system.
However, we apologise for any confusion this has caused.
Unfortunately, as stated in the original response, this means we will need to wait for the
maintenance works to be completed before we can use the system to obtain the breakdown
you have requested.
--- PDF page 3 ---
3
OFFICIAL
Turning to the timescale for the original response, we asked if you could please revert to us
when the maintenance works were complete. This further delay should not affect the
information you have requested, and I am satisfied that there would be no practical benefit to
HMRC by providing the information you requested at a later time.
I note that our response was made after the statutory deadline and that we acknowledged and
apologised for this.
Conclusion
Having carefully considered how we handled your original request, and I am satisfied that the
original response was correct but may have been interpreted in a way that was unintended.
We therefore apologise for any confusion as a result of this and for the delay to your original
response.
Appeal process
If you are not content with the outcome of this internal review you can complain to the
Information Commissioner’s Office.
Yours sincerely,
HM Revenue and Customs