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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Calculating the penalty: determining unprompted or prompted disclosure

Whether a disclosure is unprompted or prompted is an objective test. It is not what the person believed but what the particular facts and circumstances gave him reason to believe, taking into account the person’s circumstances and abilities.

A national campaign highlighting AWRS would not stop a disclosure from being unprompted.

However a disclosure would be prompted if a person made the disclosure after:

  • they became aware that we had obtained information concerning the obligation to be approved
  • we had contacted them regarding wholesale activities which relate to the obligation to be approved,  or
  • during the course of a compliance check concerning one tax liability, it becomes apparent that they have traded as an alcohol wholesaler without approval and is informed they must apply.