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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Penalties for VAT and Excise Wrongdoing: Types of wrongdoing: Deliberate but not concealed

A wrongdoing or act, see CH91050, is deliberate but not concealed when the person knows that what they are doing is wrong but still carries out the wrongdoing or act. They do not, however, take any steps to conceal what they have done.

Although the penalties for deliberate wrongdoing are civil monetary penalties, we also have a criminal investigation policy and will refer the most serious cases for consideration of criminal proceedings where appropriate.

For a practical example of a deliberate but not concealed wrongdoing, see CH93250.