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HMRC internal manual

VAT Fraud

What to consider prior to determining whether to use an intervention: making and issuing a Notice of Direction: when the measure can be applied: when the Commissioners can make a direction

The fundamental requirement for the making of a direction is set out in paragraph 6A(3) of Schedule 11 to the VATA.

The Commissioners may not make a direction under this paragraph unless they have reasonable grounds for believing that the records specified in the direction might assist in identifying taxable supplies in respect of which the VAT chargeable might not be paid.

What is meant by ‘reasonable grounds for believing’ and ‘VAT chargeable might not be paid’ is looked at in VATF35230 and VATF35240.