HMRC may assess the tax or other amount due from a person1. Thus, the person assessed is the person from whom the tax or other amount is due. A person for this purpose is a natural person or a body corporate. An unincorporated body of persons such as a partnership is not, for the purposes of VAT, a person. Although IA 1978 states that a person 'includes a body of persons corporate or incorporate', this is subject to the proviso 'unless the contrary intention appears2'. It has been held that such a contrary intention does apply for VAT purposes3. However, the legislation4 was subsequently amended and it has since been held that a VAT assessment can be validly made in the name of a firm5.
Notification of VAT assessment—partnerships
A partnership is no more than a group
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