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HMRC internal manual

Tobacco: Anti-smuggling or the duty to avoid facilitating smuggling

Initial Notices: Representations by the tobacco manufacturer


Tobacco manufacturers should be encouraged to make any written representations during, or at the end of the six-month initial notice period detailing any actions they have taken since the initial notice was issued, and the impact they expect any such actions to have. By doing this, the tobacco manufacturer has the opportunity to draw to HMRC’s attention all relevant facts which may have a bearing on the decision to issue a penalty.