MTT54200 - Administration: Payments and interest: Group payment notices - Introduction
Where a responsible member has not paid its full MTT liability within certain time limits, HMRC may issue a notice (a ‘group payment notice’) to another member of the group which requires that member (the ‘recipient’) to pay the outstanding amount. This allows HMRC to take action to recover unpaid amounts if a group’s liability has not been paid.
The unpaid MTT liability and any interest for which the responsible member is liable becomes the deemed liability of the recipient. The notice will specify a date by which this deemed liability must be paid by the recipient.
This is set out in paragraphs 34-36, schedule 14 to Finance (No.2) Act 2023.
Selecting a recipient
The group payment notice may be issued to any member of the group, or any person who was a member of the group during the accounting period to which the liability relates. The member does not need to be resident in the UK, nor an incorporated company. However, the following types of entity cannot be issued with a group payment notice:
- ring-fenced entities (except in certain circumstances, see MTT54230)
- a securitisation company
- a covered bond vehicle
- an investment entity (see MTT45110)
When selecting the recipient, HMRC will assess the resources available to the group members and the ability of HMRC to enforce collection. The choice will reflect the HMRC officer’s view of the most cost-effective way for HMRC to fully recover the outstanding liabilities.