Unjust enrichment: Managing the arrangements, including costs
It is the business’s responsibility to make the refund. HMRC’s only responsibility is to ensure that the business has met the terms of the undertaking. Under no circumstances should repayments be made by HMRC to the business’s customers.
The arrangements do not allow the business to retain some of the refund to cover its costs (Regulation 22b), as this would defeat the purpose of the arrangements. If an administration fee has been charged this can be recovered by assessment action, see section AGL9850.