VATF45220 - Basic interventions: matters to consider when determining whether to use a civil intervention: assessments and penalties: raising penalties in particular circumstances: company officer liability: engagement
Before issuing a company officer notice, HMRC is legally required to tell the company officer that we are considering this. We must give the company officer the opportunity to make representations about whether they should be made liable, and the amount of their liability.
It may be that the company officer’s representations provide evidence about the role of other company officers, leading to further investigation and a different decision.