Promoters, enablers and joint liability factsheets: CC/FS43, CC/FS62, CC/FS74, CC/FS91, JAS/FS1

HMRC's factsheet CC/FS43 says it tells you about the penalties HMRC may charge if you enable abusive tax arrangements that are later defeated, which HMRC calls 'enabler penalties'.

“This factsheet tells you about the penalties we may charge you if you enable abusive tax arrangements that are later defeated. We call these penalties ‘enabler penalties’.”

HMRC's factsheet CC/FS43 says an enabler is any person who enabled a taxpayer to use abusive tax arrangements that were later defeated.

“An enabler is any person who enabled a taxpayer to use abusive tax arrangements that were later defeated.”

HMRC's factsheet CC/FS43 says that if HMRC thinks you are an enabler of abusive tax arrangements, it will carry out a check on whether you are liable to enabler penalties, write to tell you, and ask for information and documents it needs.

“If we think you’re an enabler of abusive tax arrangements, we’ll carry out a check to find out whether you’re liable to enabler penalties. We’ll write to tell you that we’re doing this and ask you for any information and documents we need to help with our check.”

HMRC's factsheet CC/FS43 says HMRC may charge enabler penalties if all of three things apply: you enabled the arrangements on or after 16 November 2017, a taxpayer used them on or after 16 November 2017, and the taxpayer's use has been defeated.

“We may charge you enabler penalties if you enabled the use of abusive tax arrangements and (all the following): … you enabled the tax arrangements on or after 16 November 2017 … a taxpayer entered into (used) those tax arrangements on or after 16 November 2017 … the taxpayer’s use of those arrangements has been defeated”

HMRC's factsheet CC/FS43 says the penalty will be equal to the total value of your 'relevant consideration' for enabling the arrangements, with no deduction for any costs you incurred.

“The penalty will be equal to the total amount, or value, of your ‘relevant consideration’ for enabling the arrangements. There will be no deduction for any costs you incurred in enabling the arrangements.”

HMRC's factsheet CC/FS43 says that if HMRC is going to charge enabler penalties it will send a notice of penalty assessment showing the amount and how it was worked out, that you then have 30 days to pay, and that if you appeal you will not have to pay until the appeal is settled.

“If we’re going to charge you enabler penalties, we’ll send you a notice of penalty assessment. It will tell you how much you need to pay and how we have worked out the amount. You’ll then have 30 days to pay the penalty. However, if you appeal against the penalty, you will not have to pay until the appeal is settled.”

HMRC's factsheet CC/FS43 says there is a time limit for HMRC to give a notice of penalty assessment, and that the normal time limit is 12 months after the latest of several dates, one of which is the date the arrangements were defeated.

“There’s a time limit for us to give a notice of penalty assessment for enabler penalties. … The normal time limit is 12 months after the latest of: … the date on which the arrangements you enabled were defeated”

HMRC's factsheet CC/FS43 says that if you are given a notice of penalty assessment you can appeal if you disagree with the decision to charge a penalty or with its amount, and that the notice will say what to do.

“If we give you a notice of penalty assessment, you can appeal if you disagree with our decision to charge a penalty, or the amount of the penalty. The notice will tell you what to do if you disagree.”

HMRC's factsheet CC/FS43 says HMRC may publish your details as an enabler of abusive tax arrangements if it has charged you 50 or more enabler penalties, or penalties totalling more than £25,000, and that you would have no right to appeal a decision to publish but can make representations first.

“If we have charged you 50 or more enabler penalties, or one or more enabler penalties totalling more than £25,000, we may publish your details to identify you as an enabler of abusive tax arrangements. … We’ll give you the opportunity to make representations to us about whether we should publish your details. If we decide to publish, you will not have any right to appeal against that decision.”

HMRC's factsheet CC/FS43 says that if health or personal circumstances may make it difficult for you to deal with HMRC, you can tell the officer who has contacted you and HMRC will help in whatever way it can.

“If you have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer that’s contacted you. We’ll help you in whatever way we can.”

HMRC's factsheet CC/FS43 says you can ask someone else, such as a professional adviser, friend or relative, to deal with HMRC on your behalf.

“You can also ask someone else to deal with us on your behalf, for example, a professional adviser, friend or relative.”

HMRC's factsheet CC/FS44 says it tells you about the information notices HMRC may give when checking whether you or another person may have to pay a penalty for enabling abusive tax arrangements, which HMRC calls 'enabler penalties'.

“This factsheet tells you about the information notices we may give when we’re checking whether you or another person may have to pay a penalty for enabling abusive tax arrangements. We call these penalties ‘enabler penalties’.”

HMRC's factsheet CC/FS44 says that once an information notice is given, the person is legally required to give the information or documents it asks for, and that if they do not, HMRC may charge penalties.

“Once we give an information notice to a person, they are legally required to give us the information or documents or both that the notice asks for. If they do not do this, we may charge them penalties.”

HMRC's factsheet CC/FS44 says that when checking whether you or another person may have to pay enabler penalties, HMRC will normally first ask you for the information and documents it needs, and may give an information notice if you do not provide them.

“If we’re checking whether you or another person may have to pay enabler penalties, we’ll normally ask you to give us the information and documents we need. If you do not do this, we may give you an information notice.”

HMRC's factsheet CC/FS44 says the information notice will tell you what to give, how and when to give it, about any penalties for missing the deadline, and about your appeal rights.

“The information notice will tell you: … what information or documents or both you need to give us … how and when to give us what we need … about any penalties we may charge you if you do not give us the information or documents or both by the deadline … about your appeal rights”

HMRC's factsheet CC/FS44 says HMRC can ask for any information or documents if it believes it needs them for its check and it is reasonable to ask for them.

“We can ask for any information or documents or both, if we believe we need them for our check and it’s reasonable to ask for them.”

HMRC's factsheet CC/FS44 lists things an information notice cannot be used to ask for, including information you do not have and cannot get, and privileged communications between lawyers and clients about legal advice.

“We cannot use an information notice to ask you for information or documents or both: … that you do not have, and that you cannot get (or get copies of) from whoever has them … that are privileged communications between lawyers and clients, and are about getting or giving legal advice”

HMRC's factsheet CC/FS44 says you can appeal by writing to the officer who sent the notice, and that if you cannot agree you can ask for a review by an impartial officer in HMRC Legal Group or take your appeal to an independent tribunal.

“You can appeal by writing to the officer who sent you the notice telling them why you think their decision is wrong. … ask for the matter to be reviewed by an impartial officer who works for HMRC Legal Group and who specialises in review work … take your appeal to an independent tribunal”

HMRC's factsheet CC/FS44 says that if you do not comply by the deadline HMRC may charge a £300 penalty, and if you still have not complied after that it may charge daily penalties of up to £60 a day.

“If you do not comply with the information notice by giving us everything the notice asks for by the deadline, we may charge you a £300 penalty. … we may then charge you daily penalties. These may be up to £60 a day for each day that you do not comply.”

HMRC's factsheet CC/FS44 says HMRC will not charge a penalty for not complying if it agrees you have a reasonable excuse, and will instead ask you to provide the information or documents by an agreed date.

“We will not charge you a penalty if we agree that you have a reasonable excuse for not complying with the information notice. Instead we’ll ask you to give us the information or documents or both (or replacement documents) by an agreed date.”

HMRC's factsheet CC/FS44 says that if you carelessly or deliberately give inaccurate information or a document containing an inaccuracy, HMRC may charge a penalty of up to £3,000 for each inaccuracy.

“If you carelessly or deliberately give us inaccurate information or produce a document containing an inaccuracy, we may charge you a penalty of up to £3,000 for each inaccuracy.”

HMRC's factsheet CC/FS44 says that if more time is needed to give HMRC what it has asked for, the person to contact is the officer who sent the information notice.

“If you need more time to give us what we’ve asked for, you should contact the officer that sent you the information notice.”

HMRC's factsheet CC/FS44 says you can ask someone else, such as a professional adviser, friend or relative, to deal with HMRC on your behalf.

“You can ask someone else to deal with us on your behalf. For example, a professional adviser, friend or relative.”

HMRC's factsheet CC/FS61 says it is for people who are subject to a stop notice given under the promoters of tax avoidance schemes (POTAS) rules, and that it sets out the consequences of failing to comply with that notice.

“You should read this factsheet if you are subject to a stop notice given under the promoters of tax avoidance schemes (POTAS) rules. … This factsheet tells you the consequences if you are subject to a stop notice and fail to comply with that notice.”

HMRC's factsheet CC/FS61 says a stop notice is a notice given by an authorised HMRC officer to any person they suspect of promoting arrangements which meet certain conditions.

“A stop notice is a notice given by an authorised HM Revenue and Customs (HMRC) officer to any person who they suspect of promoting arrangements which meet certain conditions.”

HMRC's factsheet CC/FS61 says a stop notice requires the recipient and other persons subject to it to immediately stop promoting arrangements of the kind described in the notice.

“The notice requires the recipient and other persons subject to the notice to immediately stop promoting arrangements of the kind described in the notice.”

HMRC's factsheet CC/FS61 says you may commit a criminal offence if you continue to promote arrangements meeting the description in a stop notice, and that if found guilty you may be liable to an unlimited fine, imprisonment for up to 2 years, or both.

“you may commit a criminal offence if you (do one or both of the following): … continue to promote arrangements meeting the description specified in a stop notice … If you are found guilty of a criminal offence, you may be liable to (one or both of the following): … an unlimited fine … imprisonment for up to 2 years”

HMRC's factsheet CC/FS61 says that if you continue to promote arrangements described in a stop notice, HMRC may charge a penalty of up to £100,000, and also up to £5,000 for each person you promote the arrangements to.

“we may charge you a penalty. This can be up to £100,000 and we may also charge you a penalty of up to £5,000 for each person you promote such arrangements or proposals to.”

HMRC's factsheet CC/FS61 says the maximum amounts can be increased to £250,000 and £10,000 if you, or a person you control or have significant influence over, was also subject to a monitoring notice when a relevant promotion took place.

“We can increase the maximum amounts of the penalties to £250,000 and £10,000. We would do this if you, or a person you control or have significant influence over, were also subject to a monitoring notice when a relevant promotion took place.”

HMRC's factsheet CC/FS61 says that if you are the recipient of a stop notice and do not give copies of it to the other persons who must be notified within the time specified, HMRC may charge a penalty of up to £10,000 for each person not notified.

“If you are the recipient of the stop notice and you do not do this within the time specified in the notice, we may charge you a penalty. This will be up to £10,000 for each person that you fail to notify.”

HMRC's factsheet CC/FS61 says that if the recipient does not give HMRC the required information about the other persons subject to the notice within the time limit, HMRC may charge a penalty of up to £25,000 for each person whose details were not given.

“we may charge you a penalty of up to £25,000. We will do this for each person whose details you failed to give us.”

HMRC's factsheet CC/FS61 says that for quarterly returns required by a stop notice, penalties can be up to £5,000 for each client left off, up to £5,000 for each day a return is late, and up to £5,000 for a return containing inaccuracies.

“not sending us the quarterly return – the penalty will be up to £5,000 for each client you should have included on the return … not sending us the quarterly return on time – the penalty will be up to £5,000 for each day the return is late … sending a quarterly return that contains inaccuracies – the penalty will be up to £5,000”

HMRC's factsheet CC/FS61 says that if HMRC gives you a notice of penalty assessment, you can appeal if you disagree with the decision to charge a penalty or with its amount, and that the notice will tell you what to do.

“If we give you a notice of penalty assessment, you can appeal if you disagree with our decision to charge a penalty, or with the amount of the penalty. The notice will tell you what to do if you disagree.”

HMRC's factsheet CC/FS61 says that if you, as an individual, have health or personal circumstances that may make it difficult to deal with HMRC, you can let HMRC know and it will help in whatever way it can.

“If you, as an individual, have any health or personal circumstances that may make it difficult for you to deal with us, please let us know. We’ll help you in whatever way we can.”

HMRC's factsheet CC/FS62 says it tells you about the information notices HMRC may give under the promoter of tax avoidance schemes (POTAS) rules.

“This factsheet tells you about the information notices we may give under the promoter of tax avoidance schemes (POTAS) rules.”

HMRC's factsheet CC/FS62 explains that an information notice is a document that legally requires a person to give HMRC certain information, documents or both, and that if they do not, HMRC may charge penalties.

“An information notice is a document that legally requires a person to give us certain information, documents or both. If they do not, we may then charge them penalties.”

HMRC's factsheet CC/FS62 says that when HMRC is checking for a relevant purpose, it will normally first ask you for the information and documents it needs, and may give an information notice if you do not provide them.

“If we’re checking for a relevant purpose, we’ll normally ask you to help by giving us the information and documents that we need. If you do not do this, we may give you an information notice.”

HMRC's factsheet CC/FS62 says the information notice will tell you what to give, why you are a relevant person, what the relevant purpose is, how and when to give it, what happens if you do not comply, and about any appeal rights.

“The information notice will tell you: … what documents or information (or both) you need to give us … why you’re a relevant person … what the relevant purpose is … what happens if you do not comply with the notice … about any appeal rights if you disagree with the notice”

HMRC's factsheet CC/FS62 says HMRC can ask for any information or documents if it believes they are for a relevant purpose and that it is reasonable to ask for them.

“We can ask for any information or documents (or both) if we believe they are for a relevant purpose and that it is reasonable to ask for them.”

HMRC's factsheet CC/FS62 says that to appeal you write to the officer who sent the notice within 30 days of the date it was given, say what you are appealing against and why, and that if agreement cannot be reached you can ask for an independent tribunal to consider your appeal.

“If you want to appeal, you need to write to the officer who sent you the information notice within 30 days of the date the notice was given. You need to tell them what you’re appealing against and why. … If you cannot reach agreement, you can ask for an independent tribunal to consider your appeal.”

HMRC's factsheet CC/FS62 says you cannot appeal against an information notice that has been approved by an independent tribunal, or where the required information or documents form part of your statutory records.

“You cannot appeal against an information notice (either of the following): … that has been approved by an independent tribunal … where the required information or documents forms part of your statutory records”

HMRC's factsheet CC/FS62 says that if you do not give everything the notice asks for by the deadline, HMRC may charge an initial penalty of up to £5,000, which may be increased to up to £1,000,000 if you are subject to a monitoring notice or had control or significant influence over a person who was.

“we may charge you an initial penalty. That penalty will be up to £5,000. If you’re subject to a monitoring notice, or had control or significant influence over a person who was, the penalty may be increased to up to £1,000,000.”

HMRC's factsheet CC/FS62 says that if you still have not complied after the initial penalty, HMRC may also charge daily penalties of up to £600 a day, which may be increased to up to £10,000 a day where an increased initial penalty has been charged.

“These will be up to £600 a day for each day that you do not comply. If you’ve been charged an increased initial penalty of up to £1,000,000, then the daily penalty may be increased to up to £10,000 a day.”

HMRC's factsheet CC/FS62 says that if HMRC agrees you have a reasonable excuse for not complying it will not charge a penalty for not complying, and will instead ask for the information or documents by an agreed date.

“If we agree that you have a reasonable excuse for not complying with the information notice, we’ll not charge you a penalty for not complying. Instead we’ll ask you to give us the information or documents (or replacement documents) by an agreed date.”

HMRC's factsheet CC/FS62 says that if you carelessly or deliberately provide inaccurate information or a document containing an inaccuracy, HMRC may charge a penalty of up to £5,000, or up to £1,000,000 if you are subject to a monitoring notice or had control or significant influence over a person who was.

“If you carelessly or deliberately provide inaccurate information or produce a document containing an inaccuracy, we may charge you a penalty of up to £5,000. If you’re subject to a monitoring notice, or had control or significant influence over a person who was, the penalty may be up to £1,000,000.”

HMRC's factsheet CC/FS62 says that if you need more time to give HMRC what it has asked for, the officer who sent you the information notice is the person to contact.

“If you need more time to give us what we’ve asked for, you should contact the officer who sent you the information notice.”

HMRC's factsheet CC/FS67 says it tells you about the penalties HMRC may charge if you facilitate avoidance schemes involving non-resident promoters.

“This factsheet tells you about the penalties we may charge you if you facilitate avoidance schemes involving non-resident promoters.”

HMRC's factsheet CC/FS67 says a non-resident promoter is a person who carries on a business as a promoter and is resident outside the UK.

“A non-resident promoter is a person who carries on a business as a promoter and is resident outside the UK.”

HMRC's factsheet CC/FS67 says HMRC may charge this 'further penalty' where you are liable to pay 'original penalties' that you incurred because of activities you carried out as a member of the same promotion structure as a non-resident promoter.

“We may charge you a penalty (the ‘further penalty’) for facilitating an avoidance scheme involving a non-resident promoter where (all of the following): … you are liable to pay ‘original penalties’ … you incurred the ‘original penalties’ because of activities (called the ‘original activities’) you carried out as a member of the same promotion structure as a non-resident promoter”

HMRC's factsheet CC/FS67 says you will only be liable to a further penalty where the original penalties imposed on you relate to activities you carried out on or after 24 February 2022.

“You will only be liable to a further penalty where the original penalties imposed on you relate to activities you carried out on or after 24 February 2022.”

HMRC's factsheet CC/FS67 says the further penalty will equal the total value of all 'consideration' received by all persons who were members of the promotion structure at the time of the original activities, in connection with the facilitated proposal or arrangements and any other substantially the same ones.

“The further penalty will be for an amount that is equal to the total value of all ‘consideration’ received by all persons who, at the time of the ‘original activities’, were members of the promotion structure in connection with (both of the following): … the facilitated proposal or arrangements … any other proposals or arrangements that are substantially the same as the facilitated proposal or arrangements”

HMRC's factsheet CC/FS67 says the authorised HMRC officer may assess a lower amount if they consider this just and reasonable.

“The authorised HMRC officer may assess a lower amount if they consider this just and reasonable.”

HMRC's factsheet CC/FS67 says HMRC will send a notice of penalty assessment showing the amount and how it was worked out, that you then have 30 days to pay, and that if you appeal you will not have to pay until the appeal is determined.

“If we’re going to charge you a penalty, we’ll send you a notice of penalty assessment. It will tell you how much the penalty is and how we have worked out the amount. You’ll then have 30 days to pay the penalty. However, if you appeal against the penalty, you will not have to pay it until the appeal is determined.”

HMRC's factsheet CC/FS67 says there is a time limit for HMRC to give a notice of penalty assessment, which is 2 years from the date HMRC first became aware of the information that allows it to make the assessment.

“There’s a time limit for us to give a notice of penalty assessment relating to a penalty for facilitating an avoidance scheme involving a non-resident promoter. … The time limit is 2 years from the date we first became aware of the information that allows us to make the assessment.”

HMRC's factsheet CC/FS67 says that if you are given a notice of penalty assessment you can appeal if you disagree with the decision to charge a penalty or with its amount, and that the notice will say what to do.

“If we give you a notice of penalty assessment, you can appeal if you disagree with our decision to charge a penalty, or with the amount of the penalty. The notice will tell you what to do if you disagree.”

HMRC's factsheet CC/FS67 says 'original penalties' include one or more penalties under certain listed provisions where the total amount payable under that penalty, or those penalties, is at least £100,000.

“‘Original penalties’ are: … one or more penalties incurred under the following provisions, where the total amount payable under that penalty, or those penalties, is at least £100,000”

HMRC's factsheet CC/FS67 says that when checking whether you are liable to a penalty it may give you or another person an information notice requiring information and documents, or an inspection notice, and may charge penalties if they are not complied with.

“If we’re checking whether you’re liable to a penalty, we may give you or another person: … an information notice, which will require you, or them, to give us information and documents … We may charge you penalties if you do not do what information or inspection notices ask.”

HMRC's factsheet CC/FS67 says that if health or personal circumstances may make it difficult for you to deal with HMRC, you can tell the officer who has contacted you and HMRC will help in whatever way it can.

“If you have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer that has contacted you. We’ll help you in whatever way we can.”

HMRC's factsheet CC/FS71 says it tells you about the information notices HMRC may give when checking if you may have to pay a penalty for facilitating an avoidance scheme involving a non-resident promoter.

“This factsheet tells you about the information notices we may give when we’re checking if you may have to pay a penalty for facilitating an avoidance scheme involving a non-resident promoter.”

HMRC's factsheet CC/FS71 explains that once an information notice is given, the person is legally required to give the information, documents or both that it asks for, and that if they do not, HMRC may charge penalties.

“Once we give an information notice to a person, they are legally required to give us the information, documents or both, that the notice asks for. If they do not do this, we may then charge them penalties.”

HMRC's factsheet CC/FS71 says that when it checks whether you have to pay such a penalty, it will normally ask you for the information and documents it needs, and may give an information notice if you do not provide them.

“If we do, we’ll normally ask you to help by giving us the information and documents that we need. If you do not do this, we may give you an information notice.”

HMRC's factsheet CC/FS71 says the information notice will tell you what to give, how and when to give it, what happens if you do not comply, and about any appeal rights.

“The information notice will tell you: … what documents or information (or both) you need to give us … how and when to give us the information and/or documents … what happens if you do not comply with the notice … about any appeal rights if you disagree with the notice”

HMRC's factsheet CC/FS71 says HMRC can ask for any information or documents to help with its check if they are 'reasonably required', meaning HMRC believes it needs them for its check and it is reasonable to ask for them.

“We can ask for any information or documents (or both) to help us with our check if it is ‘reasonably required’. This means that we believe we need it for our check and it’s reasonable to ask for it.”

HMRC's factsheet CC/FS71 says to appeal you write to the officer who sent the notice within 30 days of the date it was given, say what you are appealing against and why, and that if agreement cannot be reached you can ask for a review by an independent HMRC officer or an independent tribunal.

“If you want to appeal, you need to write to the officer who sent you the information notice within 30 days of the date the notice was given. You need to tell them what you’re appealing against and why. … If you cannot reach agreement, you can ask for: … a review by an independent HM Revenue and Customs officer … an independent tribunal to consider your appeal”

HMRC's factsheet CC/FS71 says you cannot appeal against an information notice that has been approved by an independent tribunal, or where the required information or documents form part of your statutory records.

“You cannot appeal against an information notice (either of the following): … that has been approved by an independent tribunal … where the required information or documents forms part of your statutory records”

HMRC's factsheet CC/FS71 says that if you do not give everything the notice asks for by the deadline, HMRC may charge a £300 penalty, and if you still have not complied it may also charge daily penalties of up to £60 a day.

“If you do not give us everything the notice asks for by the deadline, we may charge you a £300 penalty. … we may then also charge you daily penalties. These will be up to £60 a day for each day that you do not comply.”

HMRC's factsheet CC/FS71 says that if HMRC agrees you have a reasonable excuse for not complying it will not charge a penalty for not complying, but will ask for the information or documents by an agreed date.

“If we agree that you have a reasonable excuse for not complying with the information notice, we will not charge you a penalty for not complying. However, we’ll ask you to give us the information or documents (or replacement documents) by an agreed date.”

HMRC's factsheet CC/FS71 says that if you carelessly or deliberately give inaccurate information or a document containing an inaccuracy, HMRC may charge a penalty of up to £3,000 for each inaccuracy.

“If you carelessly or deliberately give inaccurate information or produce a document containing an inaccuracy, we may charge you a penalty of up to £3,000 for each inaccuracy.”

HMRC's factsheet CC/FS71 says that if more time is needed to give HMRC what it has asked for, the person to contact is the officer who sent the information notice.

“If you need more time to give us what we’ve asked for, you should contact the officer who sent you the information notice.”

HMRC's factsheet CC/FS71 says that if you as an individual have health or personal circumstances that may make it difficult to deal with HMRC, you can tell the officer who has contacted you and HMRC will help in whatever way it can.

“If you, as an individual, have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer that has contacted you. We’ll help you in whatever way we can.”

HMRC's factsheet CC/FS74 explains that, for POTAS, a third party information notice is a document that legally requires a person to give HMRC certain information or documents for a relevant purpose in relation to a relevant person.

“For POTAS, a third party information notice is a document that legally requires a person to give us certain information or documents for a relevant purpose in relation to a relevant person.”

HMRC's factsheet CC/FS74 says it calls the relevant person the 'first party' and the person HMRC wants information or documents from the 'third party', and that in the factsheet and the notice, the reader is the third party.

“We refer to the relevant person as the ‘first party’ and we refer to the person we want information or documents from as the ‘third party’. For this factsheet and our third party information notice, you are the third party.”

HMRC's factsheet CC/FS74 says HMRC gives it because HMRC has given you a third party information notice, or intends to ask the independent tribunal that deals with tax to approve a request to give you one.

“We have given you this factsheet because (either of the following): … we’ve given you a third party information notice … we intend to ask the independent tribunal that deals with tax to approve our request to give you a third party information notice”

HMRC's factsheet CC/FS74 says HMRC may need information from a third party when checking a relevant person, for example because the first party has not been able to give or has refused to give information, or because HMRC needs to independently check records.

“we may need information from a third party. This could be because (either of the following): … the first party has not been able to give us information that we need or has refused to … we need to independently check records relating to a relevant purpose”

HMRC's factsheet CC/FS74 says that when it needs information from a third party it will usually ask the first party to agree to it sending an information notice, and that sometimes it will ask the independent tax tribunal for approval to give a third party notice.

“When we need information or documents from a third party, we’ll usually ask the first party to agree to us sending an information notice to the third party. Sometimes we’ll ask the independent tax tribunal for approval to give a third party notice.”

HMRC's factsheet CC/FS74 says a third party information notice will tell you whether the first party has agreed or a tribunal has approved it, the documents or information you must give, how and when to give them, and about any appeal rights.

“A third party information notice will tell you: … whether the first party has agreed we can give it to you or if it’s been approved by an independent tribunal … the documents or information you must give us … how and when to give us what we need … about any appeal rights”

HMRC's factsheet CC/FS74 says that before asking an independent tribunal to approve a notice, HMRC gives the third party the opportunity to make representations, which are available where the third party does not think they should give the information or documents asked for.

“Before we ask an independent tribunal to approve a notice, we’ll give you the opportunity to make representations to us. You can make representations if you do not think you should give us the information or documents we’ve asked for.”

HMRC's factsheet CC/FS74 says you may be able to appeal to the independent tribunal that deals with tax appeals, and that you cannot appeal against a notice that a tribunal has approved or that is a request for statutory records.

“If you disagree with an information notice, you may be able to appeal to the independent tribunal that deals with tax appeals. … You cannot appeal against a third party information notice that (either of the following): … has been approved by an independent tribunal … is a request for statutory records”

HMRC's factsheet CC/FS74 says that if you do not do what a third party information notice asks, HMRC may charge a penalty of £300, and a further daily penalty of up to £600 a day if you still have not done it by the time the penalty is issued.

“If you do not do what an information notice asks, we may charge you a penalty of £300. If you still have not done what the notice asks by the time we issue the penalty, we may charge you a further daily penalty. This will be up to £600 a day until you do.”

HMRC's factsheet CC/FS74 says that if you carelessly or deliberately provide inaccurate information or a document containing an inaccuracy, HMRC may charge a penalty of up to £5,000.

“If you carelessly or deliberately provide inaccurate information or produce a document containing an inaccuracy, we may charge you a penalty of up to £5,000.”

HMRC's factsheet CC/FS74 says that if HMRC agrees you have a reasonable excuse for not doing what the notice asks, it will not charge a penalty, but will ask for the information or documents by an agreed date.

“If we agree that you have a reasonable excuse for not doing what the information notice asks, we will not charge you a penalty for not doing it. However, we’ll ask you to give us the information or documents, or replacement documents, by an agreed date.”

HMRC's factsheet CC/FS74 says you can ask someone else, such as a professional adviser, friend or relative, to deal with HMRC on your behalf.

“You can also ask someone else to deal with us on your behalf. For example, a professional adviser, friend or relative.”

HMRC's factsheet CC/FS84 explains that a third party information notice is a document that legally requires you to give HMRC certain information or documents, to help HMRC check whether another person is or may be liable to enabler penalties.

“A third party information notice is a document that legally requires you to give us certain information or documents, or both. This is to help us check whether another person is or may be liable to enabler penalties for enabling abusive tax arrangements.”

HMRC's factsheet CC/FS84 says that in the factsheet 'you' means the third party, and 'another person' means the first party whom HMRC is checking is or may be liable to enabler penalties.

“In this factsheet where we say ‘you’ this means the third party. Where we say ‘another person’ this means the first party we are checking is or may be liable to enabler penalties.”

HMRC's factsheet CC/FS84 says that when HMRC is checking whether another person is or may be liable to enabler penalties, it will ask a third party for information and documents it needs, and may give an information notice if they are not provided.

“Sometimes, when we’re checking whether another person is or may be liable to enabler penalties, we’ll ask a third party to give us information and documents we need. If they don’t do this, we may give them an information notice.”

HMRC's factsheet CC/FS84 says HMRC will usually ask the first party to agree to it sending an information notice to a third party, and that it can also ask the independent tribunal to approve the issue of a third party notice.

“We’ll usually ask the first party to agree to us sending an information notice to a third party for the information and documents we need. … We can ask the independent tribunal to approve the issue of a third party notice.”

HMRC's factsheet CC/FS84 says a third party information notice will tell you the name of the person it relates to (unless the tribunal has decided it does not need to), what to give, how and when, about any penalties for missing the deadline, and about any appeal rights.

“A third party information notice will tell you: … the name of the person it relates to (unless the tribunal has decided it does not need to) … which documents or information, or both you must give us … how and when to give us what we need … about any penalties we may charge you if you do not give us the information or documents or both, by the deadline … about any appeal rights”

HMRC's factsheet CC/FS84 says that before asking a tribunal to approve a notice, HMRC will normally give the third party the opportunity to make representations to the tribunal, and that neither the third party nor the first party can attend the tribunal hearing.

“Before we ask a tribunal to approve a notice, we’ll normally give you the opportunity to make representations to the tribunal. … You or the first party cannot however attend the tribunal hearing.”

HMRC's factsheet CC/FS84 says that if you think the request is unreasonable and HMRC does not agree, you may be able to appeal to the tribunal, and that you cannot appeal against a tribunal approved notice or a request for statutory records.

“If you think the request in the information notice is unreasonable, and we don’t agree, you may be able to appeal to the tribunal. The information notice will tell you how to do this. … You cannot appeal against a tribunal approved notice or an information notice that is a request for statutory records.”

HMRC's factsheet CC/FS84 says that if the notice is not complied with by the deadline HMRC may charge a £300 penalty, and if it still has not been complied with, it can then charge daily penalties of up to £60 a day.

“we may charge you a £300 penalty. … we can then charge you daily penalties. Those penalties are up to £60 a day for each day that you don’t comply.”

HMRC's factsheet CC/FS84 says HMRC will not charge a penalty if you have a reasonable excuse for not complying, and will instead ask for the information or documents by an agreed date.

“We won’t charge a penalty if you have a reasonable excuse for not complying with the information notice. Instead, we’ll ask you to give us the information or documents (or replacement documents) or both by an agreed date.”

HMRC's factsheet CC/FS84 says HMRC may charge a penalty of up to £3,000 if you carelessly or deliberately give inaccurate information or produce a document containing an inaccuracy.

“We may charge you a penalty of up to £3,000 if you carelessly or deliberately: … give us inaccurate information … produce a document containing an inaccuracy”

HMRC's factsheet CC/FS84 says that if health or personal circumstances may make it difficult for you to deal with HMRC, you can tell the officer who contacted you, and they will help in whatever way they can.

“If you have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer who contacted you. They’ll help you in whatever way they can.”

HMRC's factsheet CC/FS84 says you can ask someone else, such as a professional adviser, friend or relative, to deal with HMRC on your behalf.

“You can also ask someone else to deal with us on your behalf, for example, a professional adviser, friend, or relative.”

HMRC's factsheet CC/FS91 tells you the consequences if you promote arrangements that are in breach of the prohibition of promotion of certain tax avoidance arrangements (POP) legislation.

“This factsheet tells you the consequences if you promote arrangements that are in breach of the prohibition of promotion of certain tax avoidance arrangements (POP) legislation.”

HMRC's factsheet CC/FS91 says the POP means you must not promote arrangements that have been, or are likely to be, marketed as a means to seek a particular tax advantage when there is no realistic prospect that the arrangements will result in it, or arrangements of a kind specified in regulations.

“The POP means that you must not promote arrangements that (either of the following): … have been, or are likely to be, marketed as a means by which a person may seek a particular tax advantage if there is no realistic prospect that the arrangements will result in the tax advantage … are of a kind specified in regulations”

HMRC's factsheet CC/FS91 says the European Convention on Human Rights gives you certain important rights, and that if HMRC is considering penalties it will tell you.

“The European Convention on Human Rights gives you certain important rights. If we’re considering penalties, we’ll tell you.”

HMRC's factsheet CC/FS91 says a person promotes arrangements if, in the course of a business or with a view to monetary gain, they communicate information to encourage another person to implement the arrangements, make them available for implementation, organise or manage any aspect of them once implemented, or arrange for others to take those steps.

“A person promotes arrangements or a proposal for arrangements if, in the course of a business or with a view to monetary gain, the person: … communicates information with a view to encouraging another person to implement the arrangements or part of the arrangements … makes the arrangements available for implementation by another person … in circumstances where the arrangements have been implemented by another person, organises or manages any aspect of the arrangements … arranges (whether directly or indirectly) for another person or persons to take the steps above”

HMRC's factsheet CC/FS91 says arrangements include any agreement, scheme, arrangement or understanding of any kind, whether or not it is legally enforceable and whether it involves one transaction or more than one.

“Arrangements include any agreement, scheme, arrangement or understanding of any kind. This applies whether or not it is legally enforceable and whether it involves one transaction or more than one.”

HMRC's factsheet CC/FS91 says that if you promote arrangements in breach of the POP you may be liable for a civil penalty or a criminal penalty, and that the maximum civil penalty is the sum of £1 million and £5,000 for each person who took part in the arrangements.

“If you promote arrangements in breach of the POP, then you may be liable for a civil penalty or a criminal penalty. … The maximum civil penalty we can charge is the sum of £1 million and £5,000 for each person who took part in the arrangements.”

HMRC's factsheet CC/FS91 says that when deciding whether to charge a civil penalty and what amount, HMRC will consider all relevant circumstances, including the number of people taking part, the amount of tax likely at risk, how far you co-operated and whether the wrongdoing was repeated or continued over an extended period.

“When deciding whether to charge a civil penalty and what amount, we’ll consider all relevant circumstances, including: … the number of people taking part in the arrangements, or targeted to take part in them … the amount of tax likely at risk in connection with the arrangements … whether and to what extent you co-operated with us … whether the wrongdoing was repeated or continued over an extended period”

HMRC's factsheet CC/FS91 lists rights it says apply when penalties are being considered: you have the right not to answer questions asked to help decide whether to charge a penalty, the amount of help you give is entirely a matter for you to decide, and you may want to get advice from a professional adviser.

“if we ask you any questions to help us decide whether to charge you a penalty, you have the right not to answer them … the amount of help you give us when we’re considering penalties is entirely a matter for you to decide … when deciding whether to answer our questions, you may want to get advice from a professional adviser”

HMRC's factsheet CC/FS91 also lists the right to appeal if you disagree about the civil penalties HMRC believes are due, the right to apply for funded legal assistance for an appeal against certain penalties, and the right to have penalties dealt with without unreasonable delay, and points to factsheet CC/FS92 for full details.

“if you disagree with us about the civil penalties we believe are due, you can appeal … you have the right to apply for funded legal assistance for dealing with any appeal against certain penalties … you’re entitled to have the matter of penalties dealt with without unreasonable delay … You can find full details about these rights in factsheet CC/FS92”

HMRC's factsheet CC/FS91 says that if HMRC gives you a notice of penalty assessment you can appeal if you disagree with the decision to charge a penalty or with the amount, and that the notice will tell you what to do.

“If we give you a notice of penalty assessment, you can appeal if you disagree with our decision to charge a penalty, or with the amount of the penalty. … The notice will tell you what to do if you disagree.”

HMRC's factsheet CC/FS91 says you are committing a criminal offence if you promote arrangements that have been, or are likely to be, marketed as a means to seek a tax advantage when there is no realistic prospect that they will result in it, or arrangements of a kind specified in regulations, and that a 'responsible person' whose actions contribute to the offence by a company, limited liability partnership or partnership may also be guilty.

“You’re committing a criminal offence if you (do one or both of the following): … promote arrangements that have been, or are likely to be, marketed as a means by which a person may seek a particular tax advantage if there is no realistic prospect that the arrangements will result in the tax advantage … promote arrangements that are of a kind specified in regulations … Any ‘responsible person’ whose actions contribute to the commission of the offence by a company, limited liability partnership, or partnership, may also be guilty of the offence.”

HMRC's factsheet CC/FS91 says that if you are found guilty of a criminal offence you may be liable to an unlimited fine, imprisonment for up to 2 years, or both, and that if you have been convicted you will not also be liable to a civil penalty for the same offence.

“If you are found guilty of a criminal offence, you may be liable to (one or both of the following): … an unlimited fine … imprisonment for up to 2 years … If you have been convicted of a criminal offence, you won’t also be liable to a civil penalty for the same offence.”

HMRC's factsheet CC/FS91 says that if health or personal circumstances may make it difficult for you to deal with HMRC, you can tell the officer who has contacted you, and they will help in whatever way they can.

“If you have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer who has contacted you. We’ll help you in whatever way we can.”

HMRC's factsheet CC/FS91 says you can ask someone else, such as a professional adviser, friend or relative, to deal with HMRC on your behalf.

“You can also ask someone else to deal with us on your behalf. For example, a professional adviser, friend or relative.”

HMRC's factsheet JAS/FS1 explains that a joint liability notice tells you that you are jointly and severally liable, with a company and with anyone else given a joint liability notice, for the relevant tax liability.

“A joint liability notice tells you that you’re jointly and severally liable with a company, and with anyone else who has been given a joint liability notice, for the relevant tax liability.”

HMRC's factsheet JAS/FS1 says it is for people who may be jointly and severally liable for the relevant tax liability of a company that has been involved in tax avoidance or evasion.

“You should read this factsheet if you may be jointly and severally liable for the relevant tax liability of a company that has been involved in tax avoidance or evasion.”

HMRC's factsheet JAS/FS1 says HMRC tells you whether you are jointly and severally liable by giving you a joint liability notice.

“We’ll tell you if you’re jointly and severally liable by giving you a joint liability notice.”

HMRC's factsheet JAS/FS1 says that where a joint liability notice is given for tax avoidance and evasion, the relevant tax liability is the amount of additional tax, penalties and interest due as a result of the company entering into tax avoidance arrangements or engaging in tax evasive conduct.

“Where we give you a joint liability notice for tax avoidance and evasion, the relevant tax liability is the amount of additional tax, penalties and interest due as a result of the company: … entering into tax avoidance arrangements … engaging in tax evasive conduct.”

HMRC's factsheet JAS/FS1 says an authorised HMRC officer can give a joint liability notice to an individual if all conditions A to E are met, including that the company is subject to an insolvency procedure or there is a serious possibility of that, and that there is a serious possibility that some or all of the relevant tax liability will not be paid.

“An authorised HM Revenue and Customs (HMRC) officer can give a joint liability notice to an individual if all the conditions (A to E) below have been met. … The company is subject to an insolvency procedure, or there is a serious possibility of it becoming subject to an insolvency procedure. … There is a serious possibility that some or all of the relevant tax liability will not be paid.”

HMRC's factsheet JAS/FS1 says condition C is that, at a time when the individual was a director, shadow director or participator in the company, one of several things applies, such as being responsible for the company entering into the arrangements or conduct, or receiving a benefit which, to their knowledge, arose from them.

“At a time when the individual was a director, shadow director or a participator in the company, (one of the following applies): … was responsible, alone or with others, for the company entering into the tax-avoidance arrangements or engaging in the tax-evasive conduct … received a benefit which, to the individual’s knowledge, arose (wholly or partly) from those arrangements or that conduct”

HMRC's factsheet JAS/FS1 says each person receiving a notice is jointly responsible for paying the entire amount due, and that the amount you are jointly responsible for will be reduced if you have paid certain penalties.

“Each person receiving a notice is jointly responsible for paying the entire amount due. The amount you are jointly responsible for will be reduced if you’ve paid certain penalties.”

HMRC's factsheet JAS/FS1 says the notice will include an offer to review HMRC's decision, that you can accept the review or appeal to the tax tribunal, and that you cannot challenge the existence or amount of the company's tax liability.

“If we give you a joint liability notice, the notice will include an offer to review our decision. If you disagree with our decision, you can accept our offer to review it or you can appeal to the tax tribunal. However, you cannot challenge the existence or amount of any tax liability of the company to which this joint liability notice relates.”

HMRC's factsheet JAS/FS1 says you can accept the offer of a review by writing to HMRC to say why you think the decision is wrong, by the later of 30 days from the date of the notice and the date shown on any extension notice.

“You can accept our offer of a review by writing to tell us why you think our decision is wrong. You must do this by the (later of): … 30 days from the date of the notice … the date shown on any extension notice we’ve given you”

HMRC's factsheet JAS/FS1 says an appeal to the tax tribunal must be made by the later of several dates, including 30 days from the date of the notice and 30 days from the date of any notice giving the outcome of a review you asked for.

“If you want to appeal to the tax tribunal you must do this by the (later of): … 30 days from the date of the notice … 30 days from the date of any notice telling you the outcome of a review you’ve asked for”

HMRC's factsheet JAS/FS1 says that if health or personal circumstances make it difficult to deal with HMRC and you need extra support, you can tell HMRC what help you need, and HMRC will work with you to put in place any reasonable or supportive adjustments.

“If your health or personal circumstances make it difficult for you to deal with us and you need extra support, please tell us what help you need. We’ll work with you to put in place any reasonable or supportive adjustments.”

HMRC's factsheet JAS/FS1 says you can also phone the tax tribunal helpline on 0300 303 5857.

“You can also phone the tax tribunal helpline on 0300 303 5857.”

HMRC's factsheet JAS/FS2 explains that a joint liability notice tells you that you are jointly and severally liable, with a company or companies and with anyone else given a joint liability notice, for the relevant tax liability.

“A joint liability notice tells you that you’re jointly and severally liable with a company or companies, and with anyone else that’s been given a joint liability notice, for the relevant tax liability.”

HMRC's factsheet JAS/FS2 says it is for people who may be jointly and severally liable for the relevant tax liability of a company because they have been connected to companies which have become insolvent with amounts due to HMRC.

“You should read this factsheet if you may be jointly and severally liable for the relevant tax liability of a company because you’ve been connected to companies which have become insolvent with amounts due to HM Revenue and Customs (HMRC).”

HMRC's factsheet JAS/FS2 says HMRC tells you whether you are jointly and severally liable by giving you a joint liability notice.

“We’ll tell you if you’re jointly and severally liable by giving you a joint liability notice.”

HMRC's factsheet JAS/FS2 says that where a joint liability notice is given for repeated insolvency and non-payment, the relevant tax liability includes any tax liability of the new company arising during the 5 years beginning with the date of the notice and while the notice continues to have effect.

“Where we give you a joint liability notice for repeated insolvency and non-payment, the relevant tax liability is (all of the following): … any tax liability of the new company that arises during the period of 5 years beginning with the date the joint liability notice is given and while the notice continues to have effect”

HMRC's factsheet JAS/FS2 says an authorised HMRC officer can give a joint liability notice if all of conditions A to D are met, and that condition A is that in the last 5 years an individual had a relevant connection to at least 2 'old companies' that were subject to an insolvency procedure and had a tax liability.

“An authorised HM Revenue and Customs (HMRC) officer can give a joint liability notice to an individual if all the conditions (A to D) below have been met. … In the last 5 years an individual had a relevant connection to at least 2 ‘old companies’ that were subject to an insolvency procedure and had a tax liability.”

HMRC's factsheet JAS/FS2 says conditions B and C are that a 'new company' is or has been carrying on a similar trade or activity to the old companies, and that the individual has a relevant connection to the new company.

“A ‘new company’ is or has been carrying on a similar trade or activity to the old companies. … The individual has a relevant connection to the new company.”

HMRC's factsheet JAS/FS2 says condition D is that the total unpaid tax liability of the relevant old companies must be more than two amounts, both of which must apply, one of them being 50% of the total amount of those companies' liabilities to their unsecured creditors.

“The total unpaid tax liability of the relevant old companies must be more than (both must apply): … 50% of the total amount of those companies’ liabilities to their unsecured creditors”

HMRC's factsheet JAS/FS2 says each person receiving a notice is jointly responsible for paying the entire amount due, and that the amount you are jointly responsible for will be reduced if you have paid certain penalties.

“Each person receiving a notice is jointly responsible for paying the entire amount due. The amount you are jointly responsible for will be reduced if you’ve paid certain penalties.”

HMRC's factsheet JAS/FS2 says the notice will include an offer to review HMRC's decision, that you can accept the review or appeal to the tax tribunal, and that you cannot challenge the existence or amount of the company's tax liability.

“If we give you a joint liability notice, the notice will include our offer to review our decision. If you disagree with our decision you can accept our offer to review it or you can appeal to the tax tribunal. However, you cannot challenge the existence or amount of any tax liability of the company to which this joint liability notice relates.”

HMRC's factsheet JAS/FS2 says you can accept the offer of a review by writing to HMRC to say why you think the decision is wrong, by the later of 30 days from the date of the notice and the date shown on any extension notice.

“You can accept our offer of a review by writing to tell us why you think our decision is wrong. You must do this by (the later of): … 30 days from the date of the notice … the date shown on any extension notice we’ve given you”

HMRC's factsheet JAS/FS2 says an appeal to the tax tribunal must be made by the later of several dates, including 30 days from the date of the notice and 30 days from the date of any notice giving the outcome of a review you asked for.

“If you want to appeal to the tax tribunal you must do this by (the later of): … 30 days from the date of the notice … 30 days from the date of any notice telling you the outcome of a review you’ve asked for”

HMRC's factsheet JAS/FS2 says that if health or personal circumstances make it difficult to deal with HMRC and you need extra support, you can tell HMRC what help you need, and HMRC will work with you to put in place any reasonable or supportive adjustments.

“If your health or personal circumstances make it difficult for you to deal with us and you need extra support, please tell us what help you need. We’ll work with you to put in place any reasonable or supportive adjustments.”

HMRC's factsheet JAS/FS3 explains that a joint liability notice tells you that you are jointly and severally liable, with a company and with anyone else given a joint liability notice, for the relevant tax liability.

“A joint liability notice tells you that you’re jointly and severally liable with a company, and with anyone else that’s been given a joint liability notice, for the relevant tax liability.”

HMRC's factsheet JAS/FS3 says it is for people who may be jointly and severally liable for the relevant tax liability of a company that has been charged penalties for facilitating avoidance or evasion.

“You should read this factsheet if you may be jointly and severally liable for the relevant tax liability of a company that has been charged penalties for facilitating avoidance or evasion.”

HMRC's factsheet JAS/FS3 says HMRC tells you whether you are jointly and severally liable by giving you a joint liability notice.

“We’ll tell you if you’re jointly and severally liable by giving you a joint liability notice.”

HMRC's factsheet JAS/FS3 says that where a joint liability notice is given for penalties charged for facilitating avoidance or evasion, the relevant tax liability is the amount of the penalty or penalties.

“Where we give you a joint liability notice for penalties charged for facilitating avoidance or evasion, the relevant tax liability is the amount of the penalty or penalties.”

HMRC's factsheet JAS/FS3 says an authorised HMRC officer can give a joint liability notice to an individual if all conditions A to D are met, and that condition A is that either a penalty has been charged by HMRC or proceedings have started before the First-tier Tribunal for a penalty under one of the listed provisions.

“An authorised HMRC officer can give a joint liability notice to an individual if all the conditions (A to D) below have been met. … Either a penalty has been charged by HMRC or proceedings have started before the First-tier Tribunal for a penalty, under any of the following provisions:”

HMRC's factsheet JAS/FS3 says conditions B and D are that the company is subject to an insolvency procedure or there is a serious possibility of it becoming so, and that there is a serious possibility some or all of the penalty will not be paid.

“The company is subject to an insolvency procedure, or there is a serious possibility of it becoming subject to an insolvency procedure. … There is a serious possibility some or all of the penalty will not be paid.”

HMRC's factsheet JAS/FS3 says condition C is that the individual was a director, shadow director or participator in the company at the time of any act or omission for which the penalty was imposed or the proceedings for the penalty had started.

“The individual was a director or shadow director of the company or a participator in it, at the time of any act or omission for which (one of the following applies): … the penalty was imposed … the proceedings for the penalty had started”

HMRC's factsheet JAS/FS3 says each person receiving a notice is jointly responsible for paying the entire amount due, and that the amount you are jointly responsible for will be reduced if you have paid certain penalties.

“Each person receiving a notice is jointly responsible for paying the entire amount due. The amount you are jointly responsible for will be reduced if you’ve paid certain penalties.”

HMRC's factsheet JAS/FS3 says the notice will include an offer to review HMRC's decision, that you can accept the review or appeal to the independent tax tribunal, and that you cannot challenge the existence or amount of the company's tax liability.

“If we give you a joint liability notice, the notice will include our offer to review our decision. If you disagree with our decision you can accept our offer to review it or you can appeal to the independent tax tribunal. However, you cannot challenge the existence or amount of any tax liability of the company to which this joint liability notice relates.”

HMRC's factsheet JAS/FS3 says you can accept the offer of a review by writing to HMRC to say why you think the decision is wrong, by the later of 30 days from the date of the notice and the date shown on any extension notice.

“You can accept our offer to review the decision to give you the notice by writing to tell us why you think our decision is wrong. You must do this by (the later of): … 30 days from the date of the notice … the date shown on any extension notice we’ve given you”

HMRC's factsheet JAS/FS3 says an appeal to the tax tribunal must be made by the later of several dates, including 30 days from the date of the notice and 30 days from the date of any notice giving the outcome of a review you asked for.

“If you want to appeal to the tax tribunal you must do this by (the later of): … 30 days from the date of the notice … 30 days from the date of any notice telling you the outcome of a review you’ve asked for”

HMRC's factsheet JAS/FS3 says that if health or personal circumstances make it difficult to deal with HMRC and you need extra support, you can tell HMRC what help you need, and HMRC will work with you to put in place any reasonable or supportive adjustments.

“If your health or personal circumstances make it difficult for you to deal with us and you need extra support, please tell us what help you need. We’ll work with you to put in place any reasonable or supportive adjustments.”