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Just looking at my APN it mentions surcharges and not penalties, 5% if not paid in full within 28 days of the date, 5% on or before 6 months of the due date, where is the other 5%
If you don't pay the APN you will be eligible to penalties and have to pay them. Feedback is even if we win you may not have the penalties refunded. Agree need more guidance however who knows for certain in this make it up as you go along scenario