MTT54220 - Administration: Payments and interest: Group payment notices - The notice, time limits, and scope

A group payment notice must include certain information and be issued within the time limits.

It may be appealed solely on the grounds that the recipient is not a member of the group.

This is set out in paragraphs 34 and 36, schedule 14 to Finance (No.2) Act 2023.

Information contained in the group payment notice

The group payment notice will specify the date by which the recipient must pay the amount. This date cannot be earlier than 30 days after the date the notice is issued.

The group payment notice must also state:

  • the amount of any tax that remains unpaid,
  • the date any tax first became payable, and
  • the member’s right of appeal.

Time limits to issue a payment notice

A group payment notice may be issued by HMRC if the amount payable has not been paid within 3 months of the relevant date.

A group payment notice may only be issued within 3 years and 6 months of the relevant date.

The relevant date

If the amount payable is assessed in a self-assessment return, the relevant date is the later of:

  • the date on which the amount must be paid,
  • the date the return is delivered,
  • the date an enquiry is completed, if a notice of enquiry is given,
  • the date on which the last notice of enquiry is given, if multiple notices are given,
  • the date of the closure notice, if an enquiry results in an amended return, or
  • the date on which an appeal is finally determined, if there is an appeal against a closure notice.

If the amount payable is assessed as a discovery assessment, the relevant date depends on whether there is an appeal against that assessment. Where there is no appeal, it is the date on which the notice of assessment is issued. Where there is an appeal, it is the date on which the appeal is finally determined.

If the amount is assessed in a determination, and the determination has not been superseded, the relevant date is the date on which the notice of the determination was issued.

Appeals against group payment notices

The recipient of the group payment notice does not have the right to appeal against the amount of the relevant liability.

The recipient may only appeal against the group payment notice itself on the grounds that it is not a person to whom the notice can be given (see MTT54200 and MTT54230). An appeal must be made in writing within 30 days of the date on which the notice was given.

Where an appeal is made, anything required by the notice to be paid is due and payable as if there had been no appeal.