The recipient of a personal liability notice (E8.1014) has a right of appeal against the decision as to the issue and content of the notice on the ground (the burden of proof of which lies on HMRC) that:
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(a)ÌýÌýÌýÌý the amount demanded does not represent contributions, interest or penalties
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(b)ÌýÌýÌýÌý the failure to pay that amount was not attributable to any fraud or neglect on his part
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(c)ÌýÌýÌýÌý he was not an officer of the relevant body corporate at the time of the alleged fraud or neglect, or
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(d)ÌýÌýÌýÌý HMRC's opinion as to whether any other officer was guilty of fraud or neglect, or as to the proportion of the amount
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Web page updated on 17 Mar 2025 17:05