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HMRC internal manual

VAT Joint and Several Liability

Making a case for applying the JSL measure: The role of IST and VAT Fraud team in the authorisation process


Once the assessment has been raised against the missing/defaulting taxable person and JSL is the recommended course of action, the case should be referred to IST (JSL1320).

Upon receiving the authorisation procedure template (JSL5050), the independent reviewing officer in IST should ensure that it has been correctly completed. If it has not been completed properly and/or if there is insufficient evidence to demonstrate that the taxable person knew or had reasonable grounds to suspect that the VAT would go unpaid, the IST Officer (ISTO) should return the form to the case officer for further enquiry.

If satisfied, the ISTO should then check with the CCT for any conflict of interest. For example, a taxable person may be subject to an ongoing criminal investigation and any subsequent joint and several liability actions at that stage may have a detrimental impact on the criminal case. In addition, the ISTO should check that debt recovery action is not being taken against the missing/defaulting taxable person.

The ISTO will also check with DMB that there are not any wider debt management policy implications.

Once these points have been checked and the ISTO is satisfied there is no reason why the case should not proceed, they should complete sections 6 and 7 of the form and refer the case to the VAT Fraud Team.

The VAT Fraud Team

The VAT Fraud Team (JSL1300) will ensure that stages of the authorisation process have been properly carried out. In cases where legal advice is required, they will also contact the Solicitor’s Office. Once satisfied with the overall process, they will endorse the authorisation procedure template at section 8, returning the form to IST.