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HMRC internal manual

Excise Assessments Interim Guidance

Notifying joint and several liability: what if we fail to notify

If a person’s liability to pay duty is affected by a decision to assess another person, that is, we know they fall within Finance Act 1994 section 14(2), but we fail to advise or notify them of that decision, we may be required to carry out a review if they ask for one.

However, we may not have to do so if, for example

  • the two persons were closely connected, eg husband and wife, or
  • the person whose liability is affected was the guarantor and the contract of guarantee required the principal to tell him about any assessments made.