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HMRC internal manual

VAT Joint and Several Liability

Debt recovery and appeals: Appeals against the issuing of a Notice of Liability

Should a taxable person believe that the measure has been incorrectly applied then he can either ask for an internal review or appeal directly to the First-tier Tribunal. This right of appeal only applies to the Notice of Liability (JSL5200), as this is the point at which a taxable person becomes jointly and severally liable (i.e. not when a Notification Letter is issued).

If any appeals are received IST (JSL1320) and the VAT Fraud Team (JSL1300) must be informed immediately.