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HMRC internal manual

VAT Civil Penalties

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HM Revenue & Customs
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Unauthorised issue penalty: Why a penalty arises: Time limits for assessing a penalty

Please note: the S 67 VATA 1994 penalty has been replaced by the VAT and Excise Wrongdoing penalty introduced by Schedule 41 Finance Act 2008. The VAT and Excise Wrongdoing penalty applies where a person makes an unauthorised issue of an invoice on or after 01/04/2010. If an unauthorised invoice has been issued before 01/04/2010 the S 67 penalty will continue to apply.

Please see the Compliance Handbook CH90000 Penalties for more information about the VAT and Excise Wrongdoing penalty.

A penalty assessment can be made within 20 years after the event giving rise to the penalty VAT Act 1994 Section 77 (1)(b) and Section 77 (4).

The event giving rise to the penalty is the date of issue of the unauthorised invoice.