MTT54290 - Administration: Payments and interest: Partnership payment notices
Source: gov.uk (2025-08-05)


Where a partnership has not paid its MTT liability within certain time limits, HMRC may issue a notice (a 'partnership payment notice') to a partner in the partnership. The partnership payment notice requires that partner (the 'recipient') to pay the outstanding amount. This allows HMRC to take action to recover unpaid amounts if a partnership’s liability has not been paid.

The recipient is required to pay any unpaid MTT liability for which the partnership is liable, and any interest on that liability. The notice will specify a date by which the liability must be paid by the recipient.

This is set out in paragraph 37A, schedule 14 to Finance (No.2) Act 2023.

See also MTT42010 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt42010) for guidance on the continuity of partnerships, and MTT51310 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt51310) for guidance on administration of dissolved partnerships.

Selecting a recipient

The group payment notice may be issued to any partner of the partnership, or any former partner who was a partner at any time during the period that the liability relates to. The partner does not need to be resident in the UK.

Where the partnership is a limited partnership, the notice can be issued to any general partner, or person who was a general partner at any time during the period that the liability relates to.

When selecting the recipient, HMRC will assess the resources available to the partners and the ability of HMRC to enforce collection. The choice will reflect the HMRC officer’s view of the most cost-effective way for HMRC to fully recover the outstanding liabilities.

Information contained in the partnership payment notice

The partnership payment notice will specify the date by which the recipient must pay the amount. This date cannot be earlier than 30 days after the date the notice is issued.

The partnership payment notice must also state:
- the amount of any tax that remains unpaid,
- the date any tax first became payable, and
- the partner’s right of appeal.
Time limits to issue a partnership payment notice

A partnership payment notice may be issued by HMRC if the amount payable has not been paid within 3 months of the relevant date.

A partnership payment notice may only be issued within 3 years and 6 months of the relevant date.

The relevant date

If the amount payable is assessed in a self-assessment return, the relevant date is the later of:
- the date on which the amount must be paid,
- the date the return is delivered,
- the date an enquiry is completed, if a notice of enquiry is given,
- the date on which the last notice of enquiry is given, if multiple notices are given,
- the date of the closure notice, if an enquiry results in an amended return, or
- the date on which an appeal is finally determined, if there is an appeal against a closure notice.
If the amount payable is assessed as a discovery assessment, the relevant date is either:
- the date on which the notice of assessment is issued, if there is no appeal against the assessment, or
- the date on which the appeal is finally determined, if there is such an appeal.
If the amount is assessed in a determination, and the determination has not been superseded, the relevant date is the date on which the notice of the determination was issued.

Appeals against partnership payment notices

The recipient of the partnership payment notice does not have the right to appeal against the amount of the relevant liability.

The recipient may only appeal against the partnership payment notice itself on the grounds that it is not currently a partner in the partnership, or was not a partner during the period that the liability relates to. An appeal must be made in writing within 30 days of the date on which the notice was given.

Where an appeal is made, anything required by the notice to be paid is due and payable as if there had been no appeal.