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HMRC internal manual

VAT Civil Evasion Penalty

From
HM Revenue & Customs
Updated
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Apportioning VAT civil evasion penalty: how the penalty should be apportioned

  1. Personal gain by one named officer - whole of penalty.
  2. Personal gain by two or more named officers - whole of penalty, but divide the penalty equally between the dishonest named officers who personally gained. Make no differential for varying degrees of dishonesty or cooperation. Exceptionally, if there is clear evidence that one dishonest named officer has gained more financially from the evasion than another, you may consider apportioning a greater percentage of the penalty to him/her.
  3. Insolvency or incipient insolvency - divide the penalty equally between the dishonest named officers. Make no differential for varying degrees of dishonesty or cooperation.