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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Trade buyers: Record-keeping - trade buyers

We do not legally prescribe the exact records that should be kept by a trade buyer who is not an approved wholesaler over and above what is already required by them under other HMRC regimes.

However, we do recommend that they keep records, in order to be able to demonstrate the provenance of goods they purchase and protect themselves from potential penalties.

When checking the records of trade buyers, you should make sure that all purchases of controlled liquor were made from approved wholesalers unless the sale is excluded. You should expect to be provided with evidence that the buyer has made checks on all of their suppliers of controlled liquor and that there is a process in place to check their supplier’s approval status periodically.

Where a buyer has made purchases that are claimed to be outside of the scope of AWRS, you should check that they have kept evidence as to the provenance of the goods.

For example, the evidence could be:

  • for incidental sales, a receipt or invoice from the supplier
  • for purchases from overseas, evidence the purchase was made directly from an overseas supplier, for example, a purchase invoice or copies or details of the relevant HMRC document to prove duty payment, (forms HM2, HM4, TRC2).
  • for sales made after an application for approval has been refused and made in the course of winding down an alcohol business, a copy of the HMRC letter to the supplier confirming the refusal of their application for approval

After 1 April 2017, if a trade buyer is found to have purchased from an unapproved wholesaler, you will need to consider raising a penalty for purchasing from an unapproved wholesaler. If the trade buyer has knowingly bought from an unapproved wholesaler then you should consider whether a criminal prosecution is appropriate. You can find further guidance on penalties and sanctions in AWRS100000. Depending on the severity of the case, if the trade buyer holds a retail licence to sell alcohol, you may also want to consider whether it is appropriate to make a referral to the relevant licensing authority, for them to consider sanctions to the business’s retail licence to sell alcohol.