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HMRC internal manual

VAT Civil Penalties

HM Revenue & Customs
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Breach of VAT Regulatory Provisions: Action to take with Regulatory Penalties: Establishing liability

Before we can establish liability to a regulatory penalty there must be a breach of a regulatory requirement. Once a breach of regulatory requirements has been established a warning letter must be issued where required, see VCP11155.

There will be no liability to a regulatory penalty if double jeopardy applies, see VCP11152 or if reasonable excuse applies, see VCP11142.

Note: Even if a person is liable to a penalty, a penalty assessment cannot be made if you are out of time.

Note: There will be no liability if the person is assessed to a default surcharge for the failure, see VCP11153.