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HMRC internal manual

VAT Civil Penalties

Reviews and appeals: Review of inaccuracies in EC Sales Statements

If the trader asks for a penalty to be reviewed, you should carefully consider the facts of the case to make sure that

  • A material inaccuracy has been correctly identified.
  • The Penalty Liability Notice (PLN) has been correctly issued and still exists.
  • Discretion and reasonable excuse have been considered.
  • The penalty calculation is correct.
  • The assessment has been made within the legal time limits.

Generally the trader should be asked to say why they disagree with the penalty.

If a reasonable excuse is accepted you should remove the penalty using form VAT651.

Further guidance on reviews and appeals can be found in the Appeals Reviews and Tribunals Guidance (ARTG)