SolvedJSL6100 | Debt recovery and appeals: Appeals against the issuing of a Notice of Liability
From HM Revenue & Customs · VAT Joint and Several Liability
Should a taxable person believe that the measure has been incorrectly applied then he can either ask for an internal review or appeal directly to the First-tier Tribunal. This right of appeal only applies to the Notice of Liability (JSL5200), as this is the point at which a taxable person becomes jointly and severally liable (i.e. not when a Notification Letter is issued).