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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Calculating the penalty: trading without approval - before calculating the penalty

You need to have established:

  • the underlying behaviour that gave rise to the failure, for example. deliberate and concealed
  • whether the disclosure was unprompted or prompted, see AWRS110700
  • the quality of disclosure, see AWRS110600.

For detailed guidance on how to calculate the penalty please see AWRS111200.