Guidance

Joint and several liability — taxation of coronavirus support payments

Updated 8 July 2026

You should read this factsheet if you may be jointly and severally liable for the Income Tax liability of a company that has received coronavirus support payments from one of the HM Revenue and Customs (HMRC) administered schemes.

We’ll tell you if you’re jointly and severally liable by giving you a joint liability notice. There is more information about joint liability notices in the section ‘What a joint liability notice is’.

Where this factsheet refers to a ‘company’, it also means a ‘limited liability partnership’.

Where this factsheet refers to ‘directors’, this means one of the following, a:

• director — as set out in section 250 of the Companies Act 2006
• shadow director — as set out in section 251 of the Companies Act 2006
• participator — as set out in section 454 of the Corporation Tax Act 2010

This factsheet at a glance

This factsheet tells you:

• what to do if you need extra support
• about joint and several liability
• what a joint liability notice is
• that we may give you a joint liability notice if certain conditions are met
• that if we give you a joint liability notice, you’ll be jointly and severally liable for the Income Tax liability
• where to find more information about joint liability notices

If you need extra support

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. You should contact the officer who wrote to you. You can also go to GOV.UK and search ‘get help from HMRC’.

You can also ask us to deal with someone else on your behalf. For example, a professional adviser, friend or relative. However, we may still need to talk or write to you directly about some things. If we need to write to you, we’ll send a copy to the person you’ve asked us to deal with. If we need to talk to you, they can be with you when we do.

About joint and several liability

Legislation introduced in the Finance Act 2020 aims to deliver fairness across the tax system by:

• recovering coronavirus support scheme payments claimed incorrectly
• influencing the behaviour of those who see insolvency as a way of avoiding their tax relating to coronavirus support payments

The purpose of joint and several liability is to make directors of companies jointly and severally liable for the company’s tax liability in certain circumstances.

It includes when an individual was responsible for the management of the company at the time the Income Tax first became chargeable and (both):

• the individual knew at that time the company was not entitled to the amount
• there’s a serious possibility of insolvency

Where this happens, we may issue a joint liability notice to the individuals that benefited from the tax evasion or avoidance.

What a joint liability notice is

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.

Where we give you a joint liability notice for the Income Tax liability due on coronavirus support payments, this is as a result of the conditions being met. Each person receiving a notice is jointly responsible for paying the entire amount due.

Conditions for giving a joint liability notice

An authorised HMRC officer can give a joint liability notice if all the conditions (A to D) below have been met.

Condition A

The company is subject to an insolvency procedure, or there is a serious possibility of becoming subject to an insolvency procedure.

Condition B

The company is subject to an Income Tax charge as a result of receiving a coronavirus support payment it was not entitled to.

Condition C

The individual was responsible for the management of the company at the time the tax first became chargeable, and the individual knew (at that time) that the company was not entitled to the relating coronavirus support payment.

Condition D

There is a serious possibility that some or all of the Income Tax liability will not be paid.

What if the company no longer exists

If the company that received the coronavirus support payment no longer exists, where we refer to you being jointly and severally liable with the company, this means you being:

• solely liable for the Income Tax liability where no other individual has been given a joint liability notice for that liability
• jointly and severally liable with anyone else that has been given a joint liability notice for the Income Tax liability

Where this factsheet refers to a company’s liability or liabilities, in the case of a company that no longer exists, this means, its liability or liabilities immediately before it ceased to exist.

More information about joint liability notices

You can find more information about joint liability notices, tax avoidance and tax evasion in our guidance. Go to GOV.UK and search ‘COVID JSL notices’.

Your appeal and review rights

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.

If you want a review

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 by (the later of):

• 30 days from the date of the notice
• the date shown on any extension notice we’ve given you

An HMRC officer not previously involved in the original decision will carry out the review. If you disagree with the outcome of the review, you can still appeal to the tribunal.

We’ll take into account anything you tell us when you ask for a review. You’ll have a chance to give more information about your case during the review.

You cannot accept our offer of a review and appeal to the tribunal at the same time.

If you want to appeal to the tribunal

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
• the date shown on any extension notice we’ve given you
• 30 days from the date of any notice telling you the outcome of a review you’ve asked for

If you appeal to the tribunal you’ll need to send them a copy of the notice at the time. If you don’t, they may refuse to consider your appeal.

Appeal in respect of company liability

If you want to appeal or take part in an appeal on behalf of the company:

• you must have been made jointly and severally liable for a tax liability of the company
• the company must be subject to an insolvency procedure
• an appeal by the company for that tax liability must either not have been made, or made but not resolved

The appeal must be made within 30 days of the date the joint liability notice is given and may be made even if a time limit for the company to appeal has expired.

More information about appeals and reviews

For more information about your appeal rights, go to GOV.UK and search ‘HMRC1’ or ‘disagree with a tax decision’.

For more information about appealing to the tribunal, go to GOV.UK and search ‘Appeal to the tax tribunal’. You can also phone the tax tribunal helpline on 0300 303 5857.