However, it is only since 2014 that HMRC has been able to issue Advanced Payment Notices to expatriates who have used disputed tax avoidance / tax minimisation schemes. These APNs mean that those under investigation must pay upfront and dispute later.
There are a number of issues to consider for expatriates under investigation, not least for high net worth individuals living abroad who may find themselves unfairly targeted as a result of political motives and internal HMRC investigation targets.
Whatever the case, and whatever the possible rights and wrongs, it is essential that expats respond promptly to local tax authorities operating on behalf of HMRC – and the first component of this should be ensuring reliable expat financial advice together with jurisdictional legal advice.
Once this has been done there may, depending on the individual case, be plenty of scope for challenging the recovery of the claimed liability using MARD procedures.
This communication is for informational purposes only and is not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. You should seek advice from a professional adviser before embarking on any financial planning activity. Whilst every effort has been made to ensure the information contained in this communication is correct, we are not responsible for any errors or omissions.
According to reports emanating from Bulgaria, 
If you live in Spain, or are thinking of moving to Spain for your retirement, it is essential that you seek expat financial advice in order to give you the best possible chance of successfully protecting and growing your wealth.