David D., London:
“I suspect the vast majority of these submissions will substantially echo the same valid points which equally apply to me. The fact i entered into the scheme when the economic landscape was considerably different, that these schemes were aggressively promoted to the point I was told by my agent that they no-longer ran Limited company structures, and that these schemes were bona fide HMRC DOTAS declared and signed off by a QC obviously counts for nothing when presented with an APN.
However, a theme which i find particularly galling is that many of us do not have readily available access to funds of this magnitude at short notice. Obtaining this amount is proving to be a challenge and forcing me into an asset fire sale which will result in further considerable tax charges. So the APN charge is effectively being grossed up. Assuming I manage to raise these funds and pay the APN, in the event of a court ruling in our favour will I be compensated for punitive additional costs i have endured? No. Even the interest rate payable is asymmetric; 3% payable by me versus 0.5% back by HMRC.
For any system to be respected and adhered to without derision and contempt, It must be seen to be fair and just. This system is neither, and therefore does not earn or deserve our respect.”