CISR85160 - CIS fraud measures: S72B Officers’ Liability: Engagement
Before issuing a company officer notice, HMRC is required to tell the company officer that we are considering this. The company officer must be given the opportunity to make representations about whether they should be made liable, and the amount of their liability.
It may be that the company officer’s representations provide evidence about the role of other company officers, leading to further investigation and a different decision.