HMAG140200 - Notification of cash transactions: detail of the scheme
Which traders must comply with the requirement to notify cash transactions?
What excise goods does the notification requirement apply to?
What alcohol related services are included in the notification requirements?
What must traders do to comply with the requirement?
What types of payments are treated as being cash?
How do traders notify HMRC of cash payments?
When are traders required to notify HMRC of cash transactions?
How should traders treat cash payments that are made in several instalments?
Suggested good practice for submitting cash notifications
Which traders must comply with the requirement to notify cash transactions?
The requirement to notify cash transactions came into force on 1st January 2006 and the following trader group must comply with this requirement:
- Warehousekeepers registered under the Warehousekeepers and Owners of Warehoused Goods Regulations (WOWGR) 1999;
Producers registered under the Finance (No.2) Act 2023 must also comply with the requirement:
- Spirits producers,
- Registered brewers,
- Wine producers, and
- Cider and other fermented products.
What excise goods does the notification requirement apply to?
The notification requirement applies to duty-suspended alcohol (i.e. spirits and spirits-based beverages, beer, wine, cider, and other fermented products).
What alcohol related services are included in the notification requirements?
Any service that a warehousekeeper or alcohol producer could reasonably be expected to provide to a customer in relation to duty-suspended alcohol. Examples of services include provision of storage, handling, packaging of goods, use of an excise movement guarantee.
What must traders do to comply with the requirement?
Notify our contact point immediately on a completed form W7 (PDF 43kb) (Notification of cash payments for alcohol goods or alcohol related services in duty suspension) of all cash payments over 10,000 euros received for the sale of duty-suspended alcohol and alcoholic beverages, or received for the provision of an alcohol related service for duty-suspended goods. Traders are also required to submit a W7 if they refuse to accept a cash payment from a customer.
What types of payments are treated as being cash?
For the purpose of this requirement cash is defined as: “cash means notes, coins or travellers cheques in any currency”. This is in line with Regulation 2 of the Money Laundering Regulations 2017.
How do traders notify HMRC of cash payments?
All W7 notification forms must be sent to the National Warehousing Process Unit (NWPU) via e-mail.
E-mail - salford.nwpu@hmrc.gov.uk
When are traders required to notify HMRC of cash transactions?
Traders are requested to submit form W7 as early as possible (i.e. without undue delay) following the receipt of cash payments or earlier if possible . For example a trader may know from the outset that they will be paid in cash and early notification will allow the processing of the W7 with any risk evaluation being undertaken prior to the dispatch of duty-suspended alcohol.
How should traders treat cash payments that are made in several instalments?
It may be commercial practice for some customers to pay cash for goods or services in two or more instalments. For example a customer may pay for a supply of goods costing £10,000 in two cash instalments of £5,000. If the total value of the sale and cash to be received exceeds the 10,000 euros notification threshold this should be notified on form W7 (PDF 43kb) when the first cash payment is received.
Suggested good practice for submitting cash notifications
Responsibility for complying with this requirement will,
- in a production site rest on the producer,
- in a warehouse rest on the warehousekeeper
Although there is no requirement to appoint and identify a particular nominated official it is strongly recommended that companies designate an identifiable contact point to deal with notifications to ensure compliance with this requirement.