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HMRC internal manual

VAT Fraud

Basic interventions: matters to consider when determining whether to use a civil intervention: assessments and penalties: particular issues to consider when raising an assessment: making an assessment where security has been paid against a repayment claim

Guidance on securities can be found in the Securities Guidance manual.

Should you need to recover any payment made to a taxable person against the provision of security then you must raise an assessment under Section 73(2). All of the same time limits as set out in VATF45121 will apply. You should note that for the purposes of the two year and four year rules the accounting period in question is the one in which the repayment or refund of VAT, or VAT credit, was paid or credited.