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HMRC internal manual

Holding and Movements Assurance Guidance

Registration and approval: reasons for refusing authorised warehousekeeper, registered owner, duty representative, registered consignor, registered consignee, temporary registered consignee, registered commercial importer and tax representative

Reasons for refusing an application for these trader types include:

  • the legal entity applying or any of its key employees have been involved in significant revenue non-compliance or fraud in other HMRC regimes;
  • ongoing proceedings for revenue offences;
  • applicant provides false information with the clear intention to deceive;
  • applicant has unspent convictions;
  • there is a proven link between key personnel/directors and other known non-compliant or fraudulent businesses;
  • the proposed business is not commercially viable or has significant credibility issues;
  • the trader cannot demonstrate a genuine business need to justify the authorisation;
  • outstanding departmental debts and no efforts have been made to pay the debt;
  • Non-compliance in other revenue regimes (for example VAT, Customs warehousing).

The list is not exhaustive.

Additionally for duty representatives if it is established that the applicant is not based in the UK , or will not be acting on behalf of a business based overseas and/or that overseas business has premises in the UK the application should be refused.

For registered consignors if you establish that the applicant is not an import freight agent (i.e. the person who declares the goods to free circulation via CHIEF or is not the receiving warehousekeeper for the imported goods, approval cannot be granted, refer toNotice 196 (HMRC website).

For registered consignees, registered commercial importers and tax representatives we cannot grant approval unless they have a deferment account. However, registered consignees and registered commercial importers can obtain authorisation to use someone else’s deferment account.