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HMRC internal manual

Cider Guidance

Registration: security: revenue risk indicators

New cider makers - all cider makers applying for registration are subjected to a structured process of pre-registration checks - CIDER02140 ‘Revenue risk’ gives further details.

Current registered cider makers - the cider maker’s compliance record is to be examined to form an overview in respect of risk posed to the revenue. To this end, the following factors (in ascending order of significance) are worthy of consideration as indicators of risk:

  • fraud/offence case history
  • penalties previously imposed
  • incidence of under declarations and/or irregularities
  • late and/or non-payment of returns or assessments
  • incidence of warning letters (for example, breaches of approval conditions)
  • reliability of cider maker’s management controls
  • cider maker’s level of co-operation in revenue matters.

If the overview indicates that a cider maker is a revenue risk, you will need to assess the deterrent effect of imposing security (CEMA section 157 refers) in relation to other available measures such as the withdrawal of approval to hold cider in duty suspense or taking future civil/criminal offence action. It is important to consider all such enforcement options and to select the most effective revenue safeguard in the prevailing circumstances.