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This publication is available at https://www.gov.uk/government/publications/notice-siva-1-simplified-import-vat-accounting/notice-siva-1-simplified-import-vat-accounting
This notice is about Simplified Import VAT Accounting (SIVA) and the approval criteria that must be met to use it.
1.1 What is SIVA?
SIVA is a scheme that allows you to reduce the level of financial guarantee required to operate a duty deferment account for VAT purposes.
The objective of this scheme is to provide compliance cost savings for legitimate businesses by reducing the level of financial security required to guarantee the payments of import VAT.
Specifically, authorised traders will be able to apply to reduce the level of financial guarantee required to operate a duty deferment account for VAT purposes only. This may mean that the cost of having a guarantee will be reduced.
To qualify you must:
- be the holder of a live Deferment Account or intend to apply for one, and
- meet all the requirements set out in the approval criteria (see section 3)
2. SIVA overview
2.1 How do I get approval?
To take advantage of this scheme and obtain authorisation for reduced security approval, you need to first check that you meet the criteria. You should then apply for SIVA by completing and returning the application form SIVA Application form (SIVA 1)
We undertake to issue an approval decision within 120 days of application. However, if we are unable to issue a decision within this period, you will be issued with an interim acknowledgement of your application. If you’re approved, you also receive guidance on the changes you need to make to your deferment account.
Access to the SIVA scheme is open to all traders who meet the SIVA approval criteria.
If you’re an agent you can also apply for SIVA approval (see section 5).
2.2 How much import VAT can I defer?
Successful applicants will be granted authority to operate a 0% guarantee for import VAT purposes only.
We will determine what level of security is required for your deferment account and the maximum amount that may be deferred in any one month. The maximum amount will be based on current or anticipated liabilities.
Please note: Any trader who is approved for reduced security for import VAT will continue to have a deferment account limit which must not be exceeded when deferring charges over a calendar month. The deferment account limit will reflect your current usage of duty deferment, which will typically reflect your current guarantee level.
You will still be required to provide a guarantee to cover other duty liabilities (for example, 100% customs, 100% excise – subject to excise partial security rules).
2.3 SIVA benefits
The benefits include:
- importers will save on compliance costs where a guarantee was previously required
- reducing the security requirements and associated costs will benefit UK Importers whatever their size, helping improve their competitiveness, and
- the reduced levels of financial security can release funds for commercial borrowing or investment in other areas of a business.
3. Approval criteria
3.1 Length of time VAT registered
You must have been VAT registered (and continuously trading) for 3 years or more. Businesses with less than 3 years VAT registration may be considered subject to further financial credibility checks.
Ideally, you’ll have been registered for VAT for at least 3 years. You can still apply if you haven’t, but you’ll be subject to additional financial and credibility tests.
If you’ve re-registered as the result of a company restructure or change of ownership and don’t therefore qualify under the 3 year rule you’ll be required to provide additional information in order to assess eligibility (that is, proof of new owners previous 3 year tax compliance, etc.).
If you rely on a previous VAT registration to satisfy the 3 year requirement, we will also assess the compliance of your previous company to ensure the approval criteria is met (unless ownership has changed in which case the new controlling company must also meet the criteria).
If you’ve previously operated in another member state and are extending or moving to the UK, you’ll be required to provide evidence of your VAT compliance in the other member state.
Note: If your VAT and/or Economic Operator Registration and Identification (EORI) number changes, for any reason, SIVA approval lapses and you must make a new SIVA application which will again have to meet the criteria.
3.2 Debtor history
If you’re in debt to the department at the time of your application you won’t qualify for SIVA.
You will also not be eligible if:
- there is a current time to pay agreement in force, or if an agreement request is being processed
- there is a current Company Voluntary Arrangement (CVA) or similar scheme in place
- there is a debt not currently under appeal
- there has been a bailiff visit within the last 2 years
- there have been 2 or more Debt Management Unit (DMU) actions within the last 3 years
- you are a continuing trader and have a write off amount outstanding
3.3 Offence record
Applicants with serious offences (proven or charged) on record with the department will be excluded from SIVA.
Note: You may re-apply 3 years after the offence action was finalised, or 5 years if a custodial term was imposed.
3.4 Deferment account history
Even as a trader authorised for SIVA you must still maintain a 100% guarantee for any customs and/or excise charges you incur, and ensure that the Deferment Account Limit (DAL) is operated within its approval limits. You must also ensure that a new schedule (form SIVA 2) is submitted to the Central Deferment Office (CDO) if you need an increase to your DAL. Failure to do so may result in you exceeding your DAL which in turn may result in the withdrawal of your SIVA approval, you will then have to provide a 100% guarantee to cover Customs Duty, Excise Duty, and VAT.
Your duty deferment payment record will be reviewed and if you have defaulted on deferment payments more than once in the 12 month period prior to application you will be refused approval.
Note: You may apply for SIVA 12 months from the last default as long as all other compliance criteria are met.
3.5 VAT compliance history
Applicants must have a good VAT compliance history and eligibility will be assessed against a number of compliance criteria, including those outlined below:
- number of errors made on VAT returns
- timeliness of rendering VAT returns
- number of assessments raised on missing VAT returns
If you have made a large, or frequent under declarations of VAT in the last 3 years, you will be excluded from the SIVA scheme.
Note: Voluntary disclosures will be ignored for approval purposes.
Note: You may apply for SIVA 3 years from the date of your last under declaration.
3.6 Default surcharges
You must not have incurred any default surcharges in the previous 12 months or be appealing against such a surcharge.
Note: You may re-apply once your last recorded surcharge is spent (or where an appeal has been heard and a judgment in your favour has been given) and you’re compliant in all other dealings with us.
3.7 Transfer of a going concern
A transfer of a going concern must have occurred more than 3 years prior to the date of application for SIVA.
Note: We will consider those transfers that are less than 3 years and are the result of a change of legal entity where a change of management structure and responsibility for VAT payments has not taken place. For example, partnership to limited company (where a change or ownership has taken place see also point 3.1 – Length of time VAT Registered).
3.8 Financial viability
You must be able to provide evidence of financial solvency which is sufficient to fulfill your commitments for the type of business concerned.
If your business is in:
- financial difficulties (time to pay arrangements, etc.)
you won’t be eligible for SIVA.
Note: You may apply for SIVA when you’re out of financial difficulties, no longer owe money to us, and remain compliant for 3 years.
3.9 Liquidity risk assessment
If you haven’t previously operated a deferment account, please note that we have a statutory responsibility to protect tax collection by making additional checks to determine whether your business will be able to meet its future deferment payments. For a non-deferment account trader, your business must have sufficient UK based realisable fixed tangible assets (this doesn’t include cash in hand or in accounts) to cover all debts that may become due to us. This amount will normally be based on your highest monthly VAT amount out of the 12 months preceding your application, that amount must then be covered by 50% of the realisable amount the sale of business owned UK based fixed tangible assets would raise.
Note: In the above situation you will be required to submit the business’s last 2 years audited accounts and have a compliant 12-month international trade operating history prior to being granted SIVA. We will also take into account, the business, its profitability, levels of realisable fixed tangible assets (not cash assets), debts, loans, creditors and debtors. A decision on granting SIVA approval will be based on those disclosures.
Note: Fixed tangible assets based outside the UK can’t be included for the purposes of HMRC liquidity risk assessment.
3.10 Record management
You must show a high level of records management. Including where necessary transport records, enabling appropriate customs controls.
3.11 Additional checks
We reserve the right to have external credit checking carried out where we consider there to be a perceived revenue risk, or where sufficient information is not available.
4. Application process
4.1 Where do I get the application forms
You can obtain the application form and questionnaire from our website:
4.2 If I make a mistake on the form
Before it is sent:
If it’s a simple mistake you may clearly cross through and initial the error and insert the correct details. Please don’t use correction fluid.
After it is sent:
If you discover that a mistake has been made after you have sent the form, please obtain a new blank application form, complete it correctly and write the word ‘Replacement’ at the top of the form. Please submit it to the address on the form.
4.3 Proof of receipt and notice of approval
We will issue a decision letter within 120 days of application. However, if we are unable to issue a decision within this period we will issue you with an interim acknowledgement of your application. You shouldn’t take this acknowledgement to mean that your application has been checked for accuracy, completeness or validity.
We will issue a decision letter to all applicants advising if they have been approved, or not.
5.1 As an agent can I apply for SIVA?
Yes. All agents, irrespective of the capacity in which they act, may apply for approval.
5.2 What about my liability for the debt?
Use of the scheme will not affect the current rules concerning liability for the customs debt. The law relating to the liability of agents for customs debt hasn’t been changed and your liability will continue to be governed by the provisions of the Union Customs Code (UCC).
Agents who act in their own name, that is, indirectly, will be held jointly and severally liable with the principal for the customs debt.
Agents who act in their principal’s name, that is, directly, wion’t be liable for the customs debt, and payment tendered via their own deferment accounts will be regarded as disbursements on behalf of the principal.
SIVA approval is a partnership of trust between the agent and customs. As such agents will be expected to honour the payment of any liabilities lodged against their own deferment account.
5.3 What will happen if I don’t pay my debt
Your approval for SIVA will be revoked. The regulations stipulate that approval for SIVA is, at all times, subject to the HMRC Commissioners satisfaction.
5.4 How can I avoid being caught up in an attempted fraud
Access to the SIVA scheme may be attractive to criminals and it’s in your interest to carefully check who you are doing business with, or on behalf of.
Once the need to supply a financial guarantee is removed, criminals may feign compliance in order to increase their liability limit before committing fraud then going missing.
You may wish to consider the risk of commodities that are known to be favoured by criminals (for example, mobile phones) and that aren’t liable to customs or excise duties, but only VAT.
We advise you to carry out checks to establish the legitimacy of your customers. There are a number of checks that you probably already undertake in line with good commercial practice such as credit checks. You aren’t expected to go beyond what is reasonable. However, we would expect you to make at least basic checks on the integrity and reliability of your customers.
The checks that you make, and the extent of them, will vary depending on your individual circumstances and your existing knowledge of the customer. Factors you may wish to include are:
- the type and level of checks previously carried out on a customer integrity, and the action you took as a consequence of those checks
- the nature of the supply of the goods (goods not from a usual country of export, etc.)
- aspects of payment arrangements and conditions (cash payment, etc.)
- details of the movement of goods involved (unusual routing, etc.)
If you have any concerns at all about a transaction please call the Customs Hotline on telephone: 0300 123 2040 .
For more information about the Hotline and other ways to give us information: Contacting HMRC.
6. SIVA approval letter
6.1 I have received my SIVA reduced security approval letter, what do I do next
After receipt of your SIVA approval letter you will need to consider the level of bank guarantee that will be required to operate your duty deferment account (to account for any Import Duty and/or Excise Duty payable), and you’ll have to submit some documents to the Central Deferment Office (CDO).
6.2 How do I determine if I need to reduce the bank guarantee amount I currently provide
You will need to address the following 3 points:
- the future use of your Deferment Approval Number (DAN) regarding the maximum import VAT, customs duties and excise duties you will be deferring in a calendar month
- how the Deferment Account Limit (DAL) and Deferment Guarantee Level (DGL) compare to the bank guarantee level you are currently providing
- supporting evidence or information may be required from you if you request an increase substantially higher than your current liabilities
6.3 Is deferment security still required now I am SIVA approved
Yes, you must maintain a 100% guarantee for any customs duties and/or excise duties.
6.4 Does this also include any duties deferred through the Customs Freight Simplified Procedures (CFSP) or the Registered Consignors scheme?
6.5 Will I be able to start deferring VAT charges immediately now that I have my SIVA approval?
No. You must first complete the necessary forms and submit them to the CDO. They will in turn write and advise you when you may start operating your deferment account with SIVA reduced security.
The forms required by CDO are:
- deferment schedule – SIVA reduced security (SIVA2), and
- C1201 (Bank guarantee) OR C1201A (Amendment to C1201 guarantee)
If you don’t already operate a deferment account, you will also have to submit an application to do so. Details on how to do this can be found in Notice 101: deferring duty, VAT and other charges.
Note: While you are waiting for your notification from the CDO, you must maintain a 100% guarantee to cover both import and excise duties and import VAT. Failure to do so may result in your goods being delayed at importation pending payment of all charges before release can take place.
7. Deferment schedule form (SIVA 2)
The SIVA 2 form is to enable you to identify (and to advise us of) a suitable account limit for deferring all future deferred import VAT charges, and where applicable, the proportion of this limit that must continue to be secured by a guarantee. You can find the form at Deferment schedule - SIVA reduced security (SIVA 2).
7.1 Why do I need to enter my deferment usage figures on the schedule (SIVA 2)?
Your current deferment guarantee limit will be reviewed using these figures.
7.2 What happens when they are reviewed?
One of two things will usually happen:
- your guarantee can either be cancelled
- your guarantee cover can be reduced
7.3 Are there any exceptions to the above?
Yes. Your guarantee cover may remain unchanged, or have to be increased if it is considered to be insufficient to meet anticipated Customs Duty charges.
7.4 How do I estimate my anticipated maximum deferred monthly charges for import VAT, Customs Duties and Excise Duties?
You estimate your monthly charges in the same way you first calculated the size of your deferment guarantee (rounded to the nearest pound). You may find it useful to refer to your previous C79 (Import VAT Certificate) documentation to determine an accurate level of import VAT paid. Periodic deferment statements also provide information on VAT, customs and excise duties paid through your deferment account.
7.5 How does doing it this way help?
By breaking down the charges in this way, it will enable you to:
- identify where reduced security for import VAT, or 100% security for any customs and/or excise duties applies, and
- calculate the level of any guarantee that will be required under the new arrangements
7.6 What happens to the figures I provide?
Using the figures you provide, we will establish a Deferment Account Limit (DAL). This will be the total of your secured and unsecured deferred amounts that you will be expected to operate within on a monthly basis.
7.7 I have more than one deferment approval number; will you set up a DAL for each number?
Yes. We will set up a DAL for each deferment approval number in addition to any DGL that may continue to be required.
7.8 What does the DGL and DAL represent?
The DGL will represent the total Customs Duty and/or Excise Duty secured charges that you will be allowed to put through your deferment account each month.
The DAL will represent a capped limit of the total deferred charges, whether secured or unsecured, that you will be allowed to put through your deferment account each month.
7.9 Will there be a limit to how much I can defer?
Yes. From the figures you provide we will determine the maximum amount that may be deferred in any one month based on your current or anticipated liabilities.
For example a SIVA approved trader having a monthly import liability of £1 million comprising:
- £600,000 Import VAT
- £200,000 Customs Duty
- £200,000 Excise Duty
would only be required to provide a deferment guarantee for £400,000.
To provide assurance for the revenue and to safeguard Customs and Excise Duty liabilities, the approved trader, whilst only providing a guarantee for £400,000, would have a capped monthly limit (DAL) of £1 million to cover anticipated maximum monthly liability.
7.10 Who should sign the completed Deferment Schedule (Form SIVA 2)?
The completed deferment schedule must be signed by a proprietor, partner, director or company secretary.
Note: As well as providing information on your DAL and DGL, return of the schedule (form SIVA 2) will also provide confirmation that you understand and accept the SIVA and deferment approval criteria.
8. Validation of schedule
8.1 When you receive my schedule (form SIVA 2) what will you be checking for?
We will check your deferment history to ensure there are no inconsistencies between the DAL you have applied for, and your current deferment usage and guarantee levels.
8.2 Who initially agrees the DAL?
The Central Deferment Office.
8.3 How will you determine the credibility of my DAL?
Your DAL will, generally, be expected to be the same as your current guarantee level.
8.4 What if there is a difference between the levels applied for and those currently guaranteed?
We will ask you to explain the reason(s) for the difference on the schedule (form SIVA 2) and, if not attached, we will ask you to supply additional documentation to support your request.
8.5 What documentation can I provide to support an increased Deferment Account Limit?
If you are an importer who, in addition to using your deferment account, also pays import VAT charges by other ‘immediate payment’ methods, or through an agent’s facilities, you must provide us with a copy of your highest monthly Import VAT Certificate (form C79) during the previous 12 months. This documentation will show the highest total import VAT, deferred and non-deferred, that you have incurred during the period. On provision of this information we will be able to set a revised DAL that more reasonably matches your maximum monthly import VAT payments.
If you are an agent who, in addition to using your own deferment account, also pay import VAT charges on behalf of other importers by other ‘immediate payment’ methods, you must provide written confirmation of the highest monthly total of all import VAT you have paid through either your DTI (Direct Trader Input) FAS (Flexible Accounting System) account or Customs Input Entry (CIE) immediate payment entries over the previous 12 months. Please ensure you specify the month that your highest monthly import VAT figure relates to in your response. Please don’t send copy FAS statements, copy CIE entries or copy drafts.
The information provided, which will be checked by us, will evidence the total import VAT that you have been paying during the period outside of the deferment system.
8.6 How will I know the account limit you allow?
You will be notified by the Central Deferment Office, in writing.
Note: The figures you provide for deferred customs and excise duties, must continue to be fully secured and should be reflected in the guarantee changes you negotiate with your guarantor. Your new guarantee amount will be used to set the DGL for your DAN.
9. Using your deferment account
9.1 What happens once my deferment schedule (form SIVA 2) has been processed and SIVA set up on my deferment account?
Once SIVA is set up and active, all charges you defer will be validated against your DAL and DGL (if appropriate).
9.2 What am I expected to do next?
You are expected to defer transactions within these limits as part of your approval criteria for operating a SIVA reduced security account and duty deferment.
9.3 What will happen if I fail to comply with the approval criteria?
Your approval is dependent on your continued compliance with all of the approval criteria (Section 3). For deferment account compliance, this means that, failure to operate within your DAL and/or DGL will result in the withdrawal of your approval and a request to submit a guarantee to cover 100% of the Import Duty/Excise Duty and VAT. This would mean that any goods relying on deferred payments to obtain clearance would be delayed until alternative payment arrangements were in place. SIVA approval will also be withdrawn if you don’t honour your direct debit payments.
9.4 If I provide a deferment guarantee, can it be used to claim any import VAT that I am unable to pay?
Yes. Under the terms of the deferment guarantee, we are able to claim each and every sum for which deferment is allowed. Although SIVA approval provides an opportunity to reduce, or even remove your guarantee cover, once any guarantee has been provided we will use it to collect any payment defaults from your deferment account (in accordance with the agreement between ourselves and your guarantor).
Note: Any payment defaults requiring us to claim from your deferment guarantee will result in the withdrawal of your SIVA approval. You’ll then need to provide full security and could even have your deferment facility withdrawn.
9.5 What if my business pattern changes?
You may apply to have your deferment account limit revised at any time. You may do this by submitting a revised deferment schedule along with any necessary supporting documentation to the CDO detailing your new amounts. You may be contacted by the CDO for further evidence if you request an increase substantially higher than your current liabilities.
9.6 What do I need to do if once approved, I find that I have underestimated my level of imports and need to raise my level of deferment guarantee?
You can arrange to have your deferment guarantee raised at any time by providing new guarantee documentation to the CDO.
9.7 Where do I send my completed deferment schedule (form SIVA 2) and guarantee documentation?
All correspondence relating to setting up a deferment account should be addressed to:
HM Revenue and Customs
Central Deferment Office
8th Floor North Central
21 Victoria Avenue
9.8 When should I aim to send my schedule (form SIVA 2) back?
Please send form SIVA 2 as soon as possible to allow CDO sufficient time for processing the changes.
9.9 Is there anything I can do to assist the process?
Yes. Please check your documentation carefully for completeness and accuracy before you send it to the CDO.
9.10 Is there a time limit for the return of my completed schedule?
Yes. If the schedule isn’t returned within 6 months of the date of your approval letter you will have to resubmit a SIVA application. Failure to return the schedule will not prevent you from re-applying for approval at a later date if you feel conditions are more suitable for you. However, it must be noted that we will reassess your eligibility for approval which will remain dependent on your continued compliance.
9.11 What if I discover a mistake after I have sent my forms back?
You should wait for the CDO to contact you by letter. You should then return any supporting documentation and correctly completed forms with a copy of the letter. You must ensure that everything is clearly marked with the following details: name, address, DAN and EORI number.
9.12 When can I expect the necessary changes to be processed?
This is dependent on how quickly you return your documentation to us. We shall aim to get the necessary changes processed to deferment accounts as soon as possible.
9.13 Will you acknowledge receipt of my deferment schedule (form SIVA 2)?
No. We won’t be acknowledging receipt of your schedule, but we’ll notify you once SIVA is set up on your deferment account and advise you of your DAL limit and the date when you can start operating your reduced security account.
10. Reducing or cancelling your deferment guarantee
10.1 What do I do?
You need to make the appropriate arrangements with your guarantor by completing either one of two forms, they are:
- deferment guarantee form C1201
- guarantee amendment form C1201A
10.2 How do I do this?
In one of two ways:
- option 1: you will need to arrange with your guarantor to notify HMRC of the reduction in the amount of your current deferment guarantee by completing form C1201A (notice of amendment to form C1201 deferment guarantee)
- option 2: you can arrange with your current (or new) guarantor to replace your current guarantee with a new C1201 deferment guarantee, for the duty amounts requiring security
10.3 Do I need to submit my new guarantee to the Central Deferment Office with my schedule?
Yes. If you send the forms individually, your application will be delayed.
Note: If you are using the notice of amendment form C1201A, please ensure the date and number of your current guarantee is completed.
10.4 My SIVA approval means I will be deferring import VAT only so I no longer require my guarantee, what will I need to do?
You will need to contact CDO and make the necessary arrangements.
10.5 How do I do this?
By sending an official letterhead cancelling your current guarantee with effect from the date your SIVA deferment changes become operational.
10.6 Who should complete the letter?
The letter should be completed by either yourself as the deferment holder or your guarantor.
10.7 What information do I need to include on the letter?
You should include your DAN and details of the guarantee.
10.8 Can I cancel my guarantee before I am notified?
If you do cancel your guarantee before you receive notification from the CDO you will not be able to defer any Customs Import Duty or Excise Duty or VAT through your duty deferment account. This would mean you would need to make alternative arrangements to make payment prior to clearance of any goods imported.
10.9 What happens once my application is processed?
The CDO will send written notification to you and your guarantor that the guarantee is to be cancelled and the date of return to the guarantor.
10.10 When will my guarantee be returned if I decide to cancel or replace it?
The CDO will return your guarantee to the guarantor once all outstanding deferment liabilities, covered by the guarantee, have been paid.
10.11 When is that likely to happen?
Approximately 2 months from the date you start operating the SIVA reduced security scheme.
Note: For this reason, where you intend to reduce your guarantee, we strongly recommend that you arrange to amend your guarantee using the C1201A method. This will avoid the need to have more than one guarantee in force during the interim period before old guarantees can be returned.
11. SIVA monitoring
11.1 How will my SIVA deferment limit be monitored?
The department’s declaration processing system Customs Handling of Import and Export Freight (CHIEF) will monitor deferred liability across all taxes to ensure that the DAL isn’t exceeded.
11.2 What do I do if I am reaching my guarantee limit?
A temporary guarantee will be required to secure the entry and further clearances within the calendar month.
Non-CFSP entries can pay by cash or use an alternative DAN – providing they are authorised to use the DAN.
CFSP entries must be paid through Duty Deferment; either by providing a temporary/additional guarantee to cover their liabilities or use an alternative DAN – providing they are authorised to use the DAN.
Note: Your SIVA approval is dependent on your continued compliance. Failure to operate within your DAL and/or DGL may result in the withdrawal of approval, and a request to submit a guarantee to cover 100% of the Import Duty/Excise Duty and VAT. This would mean that any goods relying on deferred payments to obtain clearance would be delayed until alternative arrangements were in place.
12. Appeals/review process
12.1 How do I appeal?
If you do not agree with any decision issued to you there are 3 options available. Within 30 days of the date of the decision you can either:
- send new information or arguments to the decision maker
- request a review of the decision by someone not involved in making the disputed decision
Your request must be in writing and should set out the reasons why you don’t agree with the decision.
Please write to:
Review and Appeals Team
7th Floor South West
21 Victoria Avenue
- appeal direct to the Tribunal who are independent of HMRC.
If you opt to have your case reviewed you will still be able to appeal to the tribunal if you disagree with the outcome.
Further information relating to reviews and appeals is contained in leaflet HMRC1: HM Revenue and Customs decisions - what to do if you disagree which can be obtained from our website or by telephone: 0300 200 3700.
12.2 Can my approval to operate SIVA be suspended or revoked?
Yes. Ongoing approval to operate SIVA will be dependent upon your continued compliance with the SIVA criteria.
12.3 What will happen if my approval to operate SIVA is withdrawn?
If we have to withdraw your approval to operate a reduced guarantee you will be required to supply a 100% guarantee, immediately to cover all further liabilities. Failure to supply a full guarantee will result in your deferment account limit being reduced or your deferment account being inhibited.
Do you have any comments or suggestions?
We would be pleased to receive any comments or suggestions may have about these notes. Please write to:
HM Revenue and Customs
SIVA Policy Team
10th Floor North Central
21 Victoria Avenue