David Tipping considers the various statutory provisions that enable HMRC to make a company director liable for the tax debts of the company.
There are multiple different ways in which a company director may ultimately become responsible for a company’s tax debts.
The first part of this article considers the powers and remedies available to HMRC under general insolvency law as a creditor of an insolvent company. Part two examines the regime of joint liability notices (JLNs) introduced in Finance Act 2020. Finally, part three highlights various regimes in relation to specific taxes or penalties which enable HMRC further opportunities to pursue company directors for the taxes of their companies.
1. HMRC’s rights as a creditor
A company’s taxes, once assessed, are recoverable by HMRC as a debt. If the company is unable to pay its debts, HMRC
