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Covid-19 and joint and several liability notices

15 November 2021
Issue: 4817 / Categories: News

HMRC has published new guidance setting out the circumstances when it can issue a taxpayer with a joint and several liability notice (JLN) for a company or a limited liability partnership (LLP) that has received coronavirus support payments.

HMRC can issue these notices to directors shadow directors and other individuals connected to a company or to members or shadow members of an LLP if four conditions have been met:

  • the company or LLP is subject to an insolvency procedure or there is a serious possibility of becoming subject to one;
  • the company or LLP is liable to an income tax charge as a result of receiving a coronavirus support payment it was not entitled to receive;
  • the individual was responsible for the management of the company or LLP at the time the tax first became chargeable and the individual knew (at that time)...

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