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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and sanctions: when is a penalty chargeable for TWA?

After the application window, a penalty is chargeable if a person starts trading without approval or applies for approval but starts trading before they receive a decision from us.

A Person (P) could be one of the following:

  • an individual
  • a company
  • a partner
  • a partnership
  • a limited liability partnership
  • a member of an AWRS group.

Where a penalty for deliberate behaviour is attributable to a company officer’s actions, we can transfer all or part of the liability to pay the penalty to the officer.

Members of an AWRS group are jointly and severally liable for any penalties issued to the representative member.

We cannot charge a penalty if the person had a reasonable excuse for not applying at the appropriate time, and the penalty was not deliberate see AWRS101100 for further details.

A business must apply for approval before they start to trade as a wholesaler. There is no allowable period of trading before they have to apply so even a business who trades for a short period and then applies has traded without approval.   This is because a wholesaler must prove to HMRC they are fit and proper before they can start trading.