If payment or a valid appeal is not received within 40 days of
issuing a Notice of Determination (
IHTM38281) you should refer the
determined liability to the Solicitor of HMRC recommending the
institution of proceedings to secure a money judgement (
The Solicitor should be warned that it might be necessary to seek leave to serve the Writ outside the jurisdiction.
The Court may so order simply on the ground that the tax is unpaid.
Even if the taxpayer is outside the jurisdiction and appears to have no property here, it may still be worthwhile securing judgement against him if a substantial amount of tax and interest is at stake.
With such a judgement in hand, if the taxpayer can be located on return to this country at some later time, the Solicitor should be able to obtain an order for payment.