E4.923 HMRC Guidance On The Issue Of Transfer Notices

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Commentary

Personal and employment tax

Transfer notices have a strict hierarchy in the legislation, as resort to the third category of specified person is always regarded as 'recovery of the last resort'. However, HMRC's guidance introduces a further strand of hierarchy, and indicates that the order of issue of transfer notice will be¹:

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•�� first to persons in the first category of specified person, that is directors, officers and associates of the MSC. Only

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E5.607 Corporate members

E5.406A Employees of European Union institutions—tax exemptions

E4.507S Operation of the charge on securities with artificially enhanced market value

I7.323 APR and successions

I9.421 Situs of simple contract debts for IHT

B3.340A Hire purchase of plant and machinery and similar contracts

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