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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Revocation: revocation of an approval


The approval of existing wholesalers who appear to be falling short of an acceptable level of compliance, or who are deemed to be a risk, will be reviewed and considered for revocation.

Possible reasons for revoking an approval will match those found at AWRS30400 which deal with the refusal of applications. In addition, you should also consider the following in deciding whether or not revocation is appropriate:

  • the legal entity or its key employees continue to demonstrate non-compliance in this or other HMRC regimes
  • key personnel have been replaced by persons with a proven history of revenue fraud or non-compliance
  • key personnel have been found to be involved in revenue fraud
  • failure to comply with excise legislation and HMRC requirements; for example, failure to notify any material change in the business, such as a change of principal place of business
  • persistent or serious failures to comply with specific AWRS conditions or requirements, for example, due diligence; record-keeping and so on.
  • failure to act on any warning letters that have been given.

How we should act

Before proceeding with revocation you should ensure that:

  • we are acting fairly and proportionately to the business
  •  we have communicated the potential for revocation at an early stage
  • we act quickly to avoid delay
  • we have considered other measures that could address the revenue risk, for example additional conditions
  • all decisions are fully recorded
  • all relevant evidence is considered prior to action (all evidence is disclosable to the business and any tribunal or court)
  • evidence must be facts not suspicions.

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