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HMRC internal manual

VAT Joint and Several Liability

Making a case for applying the JSL measure: The Notice of Liability

The ISTO must consider the case officer’s recommendation ensuring consistency of application. If s/he considers the explanations provided by the taxable person are satisfactory s/he should refer the case back to the case officer requesting that the taxable person be informed that a Notice of Liability will not be issued to him in relation to the transactions in the Notification Letter (JSL5150). If s/he considers the explanations provided by the taxable person are unsatisfactory s/he should complete sections 11 and 12 of the authorisation procedure template (JSL5050) and prepare a Notice of Liability.

The ISTO should also check with the CCT to confirm whether or not any conflict of interest in the application of the measure has arisen since the issue of the Notification Letter. The ISTO should also check with DMB that there are no policy or operational implications with issuing the Notice of Liability. This is to ensure, for example, that some or all of the defaulter’s debt has not been recovered since the Notification Letter was issued. The authorisation form can then be sent to the VAT Fraud Team (JSL1300).

The VAT Fraud Team will ensure that all the procedures have been observed, liaise with the Solicitor’s Office if required, and if satisfied confirm that the Notice of Liability should be issued by completing section 13 of the authorisation form and referring the case to IST (JSL5100) to issue the Notice of Liability.

To ensure that the measure has been appropriately applied a full audit trail must be kept, using the decision log in section 14.