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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Fit and Proper test: evidence of illicit trading

When making a decision you must base it on sound evidence, disclosable at tribunal, that approving the application, or allowing the approval to continue, would pose a serious threat to the revenue. Examples of evidence that we should consider when assessing the fit and proper status of any key persons would include:

  • assessments for duty-unpaid stock or for other under declarations of tax that suggest there is a significant risk that the business would be prepared to trade in duty unpaid alcohol
  • seizures
  • penalties for wrongdoing  or other civil penalties which suggest a business does not have a responsible outlook on its tax obligations
  • trading with unapproved persons
  • evidence of fraud
  • serious non-compliance with other taxes
  • previous approvals revoked or refused for this or other regimes including liquor licensing, previous confiscation orders and recovery proceedings under the Proceeds of Crime Act
  • key persons have been disqualified as a director under company law.


This is not intended as an exhaustive list. Other evidence gathered may be relevant in the circumstances of any particular case.

The business must be informed of any evidence upon which refusal or revocation is based. You must not use evidence unless it has been notified to the business.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)