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HMRC internal manual

VAT Civil Penalties

Misdeclaration penalty: Calculation and notification of a misdeclaration penalty: Form VAT 291 what to include

Please note: VAT Misdeclaration Penalty has been replaced by the Schedule 24 inaccuracy penalty for all accounting periods where the return period commences on or after 01/04/2008 and the due date is on or after 01/04/2009. Misdeclaration penalty will still apply where the due date is before 01/04/2009.

Please see the Compliance Handbook CH80000 Penalties for Inaccuracies for further details.

The following information must be included on the Form VAT291

  • Name and address
  • LVO Code
  • Date of issue: Date notification sent to trader
  • VAT registration number
  • Penalty Code = From D2211 Type of Penalty

    • MP = Code 08
    • MP(R) = Code 10
  • Default date from: start date of the VAT Penalty Period
  • Default date to: the last day of the VAT Penalty Period
  • Penalty rate: 15% in all cases even when mitigation given
  • Penalty period: must be a live VAT period
  • Total penalty payable in whole pounds (£) only
  • Assessing officer signature
  • Checking Officer signature: where the penalty calculation has been checked
  • Countersignature: see below
  • For LVO use: Trader’s name, LVO code, registration number and assessed amount


Form Officer Higher Officer SO Grade 7
VAT 291 £20,000 £50,000 £1 million No limit
VAT 651 £20,000 £50,000 £1 million No limit

These limits are only recommendations. The decision on setting the countersigning limits has been delegated to Local Offices.

Note: Both copies of the VAT 291 should be headed in red “VCP10812 Letter issued” and the trader’s copy of the letter filed with the penalty papers.