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HMRC internal manual

VAT Joint and Several Liability

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HM Revenue & Customs
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Establishing whether the JSL measure should be applied: Establishing whether the taxable person 'knew or had reasonable grounds for knowing': General awareness

You will need to consider evidence of the taxable person’s general awareness of MTIC fraud at the time the transactions took place. This should include, but is not limited to, the following:

  • details of warnings given, whether in writing or by means of conversations by telephone or on visits, which informed the taxable person of the risks of MTIC fraud and/or its characteristics
  • any record of acknowledgements by the taxable person, whether in writing or in discussions, of a knowledge or understanding of those risks and characteristics
  • frequency and extent in previous periods of taxable person’s involvement in transaction chains traced to a VAT loss. What proportion of all the taxable person’s transactions did this represent? How many different suppliers were involved in each period? To what extent was the taxable person made aware of these findings?
  • Involvement of key personnel in the running of other businesses with known involvement in MTIC transaction chains.

Further indicators can be found in section VATF60000 of the VAT Fraud guidance manual.