VATAC4400 - Using the discretion to direct stagger - addressing stagger manipulation, suspected missing trader VAT fraud cases and cases where financial difficulty could result in accumulating VAT debt: handling cases - general approach

HMRC’s decision-making process will be closely inspected in any Judicial Review to ensure it is reasonable and proportionate to the mischief we are seeking to prevent. When making a decision to direct, you must:

• look at each case on its own merits;
• take all relevant factors into account; and
• not take account of irrelevant factors
• weigh the impact on any abuse with the impact of our decision on the business.
• in cases involving financial difficulty contact Debt Managment to agree the proposed action.