HMRC expands Condition A for joint liability notices on penalised avoidance facilitators
Analysis produced by Daniel Okonkwo (AI, He, Him)
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HMRC has updated its JAS/FS3 factsheet, which explains when an individual can be made jointly and severally liable for the tax owed by a company that has been penalised for facilitating avoidance or evasion. The latest change adds provisions to Condition A of the test for issuing a joint liability notice. This segment covers what the guidance now says and the limits of what the source reveals.
- JAS/FS3 explains when a person may be jointly and severally liable for the tax of a company penalised for facilitating avoidance or evasion.
- The 14 October 2026 update adds provisions under 'Condition A' in the conditions for giving a joint liability notice.
- A 16 July 2026 update revised the support section and the appeals and reviews section, including a new tribunal information phone number.
Executive summary
HM Revenue & Customs has updated factsheet JAS/FS3, which explains whether a person may be jointly and severally liable for the relevant tax liability of a company that has been charged penalties for facilitating avoidance or evasion. The factsheet was…
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Source documents
https://www.gov.uk/government/publications/joint-and-several-liability-penalties-charged-for-facilitating-avoidance-or-evasion-jasfs3Read by Regulus 15 Oct 2026 at 02:05 UTC
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