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HMRC internal manual

VAT Joint and Several Liability

Introduction: Where to obtain assistance and guidance: HMRC teams: VAT Fraud Team

The VAT Fraud Team is part of the VAT Directorate, based at 100 Parliament Street, London, and has responsibility for:

  • policy and legislation for civil intervention and litigation to counter VAT fraud, including the reverse charge for specified goods and services
  • the Kittel principle, including formulation and guidance
  • all VAT fraud civil litigation
  • Joint and Several Liability, including drafting and publishing Notice 726 and associated policy guidance
  • the policy on ‘Input Tax deduction without a valid VAT invoice’ Statement of Practice
  • advising on the policy aspects of judicial reviews and other civil litigation involving VAT fraud, including tort of conspiracy;
  • providing advice to Specialist Investigations, Local Compliance and Large Business Services compliance staff on when and how to use a VAT civil intervention
  • monitoring and advising on new variants of VAT fraud; and
  • monitoring and advising on VAT fraud in relation to VAT policy or legislative changes, or new processes.

The VAT Fraud Team is not responsible for the following:

  • HMRC’s criminal investigation policy;
  • Civil Investigation of fraud policy including COP9;
  • Civil Investigation of evasion under PN160, PN161 and PN300; and
  • HMRC forfeiture policy under PN12A (Seizure and Restoration).

The above are the responsibilities of the Investigation and Civil Enforcement Policy Team.