This Practice Note outlines the circumstances in which, in certain insolvency-related circumstances, HMRC can give a joint and several liability notice (JLN) under Schedule 13 or para 15 of Schedule 16 to the Finance Act 2020 to an individual that is involved in the management of a company or a limited liability partnership (LLP) (and certain other individuals) where the notice makes the individual jointly and severally liable for the tax debts of that company or LLP. This Practice Note is produced in partnership with David Irvine and Nathan Langford of Kirkland & Ellis LLP.
This Practice Note considers various corporate insolvency procedures, such as liquidation (or winding up), administration, appointment of a receiver and a company voluntary arrangement (CVA) and outlines the possible tax consequences for the company in that procedure. This Practice Note was produced in partnership with David Irvine of Kirkland & Ellis LLP, Nathan Langford of Kirkland & Ellis LLP and Philip Ridgway of Temple Tax Chambers.
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