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HMRC internal manual

VAT Civil Evasion Penalty

HM Revenue & Customs
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Liability to a VAT civil evasion penalty: failure to notify cases

In cases where the trader has failed to register for VAT on time, the act of evasion will generally have taken place on the date from which the trader should have been registered for VAT. This date will depend on the registration rules in force at the time, which are explained in separate books of guidance on registration. It is possible, however, that a trader may have failed properly to register from a certain date, but only have been dishonest in relation to that failure from a later date. See Prebble & Prebble (No. 2) v. C&E [2005] UKVAT 19331.