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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: what is meant by 'VAT chargeable might not be paid'?

It is important to note that the wording of the legislation states ‘might’. It also does not specify where that non-payment should occur - with the taxable person himself, elsewhere in the chain of transactions or even in a transaction chain not involving the taxable person (e.g. in a case involving contra trading (VATF23550)).

In order to show that VAT ‘might not be paid’ you should use the evidence collected when looking at whether there are ‘reasonable grounds for believing’.