Guidance: Joint and several liability — penalties charged for facilitating avoidance or evasion — JAS/FS3

Imported from official source

You should read this factsheet if you may be jointly and severally liable for the relevant tax liability of a company that has been charged penalties for facilitating avoidance or evasion.

We’ll tell you if you’re jointly and severally liable by giving you a joint liability notice. There is more information about joint liability notices in the section ‘What a joint liability notice is.’

Where this factsheet refers to a ‘company’, it also means a ‘limited liability partnership’.

Where this factsheet refers to ‘directors’, it also means one of the following, a:

  • director — as set out in section 250 of the Companies Act 2006
  • shadow director — as set out in section 251 of the Companies Act 2006
  • participator — as set out in section 454 of the Corporation Tax Act 2010
  • that we may give you a joint liability notice if certain conditions are met
  • that if we give you a joint liability notice, you’ll be jointly and severally liable for the relevant tax liability
  • how we might reduce the amount you’re jointly and severally liable for
  • where to find more information about joint and several liability notices
  • If your health or personal circumstances make it difficult for you to deal with us and you need extra support, please tell us what help you need. We’ll work with you to put in place any reasonable or supportive adjustments. You should contact the officer who wrote to you. You can also go to GOV.UK and search ‘get help from HMRC’.

    You can also ask us to deal with someone else on your behalf. For example, a professional adviser, friend or relative. However, we may still need to talk or write to you directly about some things. If we need to write to you, we’ll send a copy to the person you’ve asked us to deal with. If we need to talk to you, they can be with you when we do.

    Legislation introduced in the Finance Act 2020 aims to deliver fairness across the tax system by:

  • deterring the use of tax avoidance and tax evasion
  • This is an extract. The publication continues at the source.

    Contains public sector information licensed under the Open Government Licence v3.0. Licence

    Read the original at the source: https://www.gov.uk/government/publications/joint-and-several-liability-penalties-charged-for-facilitating-avoidance-or-evasion-jasfs3

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    October 14, 2026 07:01
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    https://www.gov.uk/government/publications/joint-and-several-liability-penalties-charge...

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