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HMRC internal manual

VAT Civil Evasion Penalty

HM Revenue & Customs
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Apportioning VAT civil evasion penalty: transfer of liability after penalty is imposed

Once a penalty has been imposed on a company and circumstances change, for example the company goes into liquidation, the liability for the penalty should not subsequently be transferred to the directors/managing officers/managing members. You should never transfer liability to the penalty to a person because of non-payment by another.