It forced HMRC to carry out a review, which took 6 months.
Obviously it did the trick.
But, even if it hadn't been successful, it would have made HMRC justify why the scheme was notifiable, and bought time.
In another case we've come across, HMRC rejected an LoR based on an incorrect reason why a scheme was notifiable. This has allowed a further challenge of the APNs.
It's probably best not to copy this letter verbatim and, instead, come up with your own entirely different wording. I trust I don't need to explain why.
Dear Sir
I refer to your Accelerated Payment Notice (“APN”) dated [ ] for the tax year [ ].
Please accept this letter as my objection to the Notice on the grounds that the particular arrangement referred to by you as DOTAS number [ ] was not a notifiable arrangement as defined in the APN provisions. I would be grateful therefore if you would withdraw the Notice.
Yours faithfully,
