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HMRC internal manual

VAT Civil Penalties

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Belated Notification Penalty: When Does A Penalty Arise: Relevant supplies

Belated Notification Penalty has been replaced by the Failure to Notify penalty introduced by Schedule 41 of the Finance Act 2008. The Failure to Notify penalty applies to obligations to notify HMRC of a liability to be registered for VAT on or after 01/04/2010. The Belated Notification Penalty under Section 67 VATA 1994 continues to apply to obligations to notify a liability to be registered for VAT before 01/04/2010.

Please see the Compliance Handbook CH70000 for more details about the new failure to notify penalty.

Relevant supplies - for periods of late notification from 21 March 2000

Relevant supplies for periods of late notification from 21 March 2000, are covered by the VAT Act 1994 Schedule 3A, paragraphs 3 and 4.

If the trader makes relevant supplies, notification must be made to HMRC within 30 days of the day the first relevant supply is made or within 30 days of the day the trader first expected to make relevant supplies.

Note: There is no threshold limit.

Relevant supplies - trader exempt from registration - for periods of late notification from 21 March 2000. 

Relevant supplies for a trader exempt from registration for periods of late notification from 21 March 2000 are covered by the VAT Act 1994, Schedule 3A, paragraphs 7(2) or 7(3).

If there is a material change in the nature of the trader’s supplies the trader must notify HMRC

  • within 30 days of the date on which the change occurred, or
  • if no particular date is identifiable, within 30 days of the end of the quarter in which the change occurred.

If there is a material alteration in the proportion of zero rated supplies in any quarter, the trader must notify HMRC within 30 days of the end of the quarter.