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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: failure to comply with the direction: reasonable excuse

The taxable person will not be liable to a penalty if he can establish that he had a reasonable excuse for his non-compliance. Reliance on a third party (e.g. to complete the records) is not acceptable as a reasonable excuse, as per Section 71 of the VATA.