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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Calculating the penalty: introduction

The penalty for trading without approval is calculated using a starting maximum, called the ‘maximum amount’ which is £10,000. AWRS behavioural penalties differ to other penalties available under Finance Act 2008, Schedule 41 as there is no potential lost revenue on which to base the penalty calculation. This is because a wholesaler who should be approved is dealing in alcohol at or after an excise duty point and is, therefore, not normally the duty payer. There could be occasions where a wholesaler fails to apply for approval but their goods are all duty paid and therefore there is no potential lost revenue.

You must work out the amount of the penalty by applying the appropriate percentage to the maximum amount depending on whether the contravention is:

  • deliberate and concealed,
  • deliberate but not concealed, or
  • non-deliberate.