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HMRC internal manual

Securities Guidance

Security as a condition of releasing a VAT credit: the amount of security

Pre-verification

Security should only be required up to the value of the payment being made to the person, after making allowance for any legitimate input tax claimed.

You should not ask for more than is necessary for protecting revenue that may be at risk if a repayment is made.

Post-verification

Security should only be required up to the value of the potential joint and several liability as set out in the Notification Letter issued to the person.

You should not ask for more than is necessary for protecting the revenue.