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HMRC internal manual

VAT Accounting Manual

Using the discretion to direct stagger - addressing stagger manipulation and suspected MTIC fraud cases: right of appeal and Judicial Review

HMRC’s legal power to issue a direction to amend a business’ stagger (or to refuse monthly returns or a change of stagger) is particularly contentious since there is no right of appeal to a Tribunal. The only avenue open to businesses that object to the change of stagger is to seek a Judicial Review which can be both costly and time-consuming for all parties.

Any instance where the business has applied for Judicial Review should be reported immediately to the policy team.