Taxes Management Act 1970 section 107A

Relevant trustees

Section 107A deals with how tax obligations, penalties and liabilities are shared among the trustees of a settlement, and the circumstances in which HMRC may recover amounts from individual trustees.

• Any action taken by or in relation to one or more relevant trustees of a settlement is treated as having been done by or in relation to all of the relevant trustees.
• Where relevant trustees are liable for penalties, interest or tax payments, HMRC may recover the amount from any one or more of them, but only once in total.
• A person who becomes a relevant trustee after the "relevant time" (the point at which the liability arose) cannot be pursued for penalties or interest that relate to events before they became a trustee.
• The "relevant time" varies depending on the type of penalty or interest, and is either the date of the act or omission that triggered the penalty, the beginning of the penalty date, or (for certain reporting requirement penalties) the end of the relevant reporting period.