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HMRC internal manual

VAT Civil Penalties

Unauthorised issue penalty: Reconsiderations and Appeals: Review of appeal cases

Please note: the S 67 VATA 1994 penalty has been replaced by the VAT and Excise Wrongdoing penalty introduced by Schedule 41 Finance Act 2008.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.

Consideration of possible reasonable excuse or mitigable circumstances should be carried out immediately upon receipt of an appeal if it has not already been done.

All cases are to be reviewed by the Appeals Team, regardless of whether policy advice has been previously sought.

If policy advice has been given prior to a trader lodging a formal appeal, and the appeal papers lodged by the trader contain further information not previously considered, you should obtain further policy advice before completing the review, see VCP11221.