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HMRC internal manual

VAT Registration

Non-established taxable persons (NETPs): fit and proper VAT representatives for NETPs


From 7 November 2016, the Department has the power to refuse to register a person as a VAT representative, or to cancel a person’s registration as a VAT representative, if they are satisfied that the person is not a fit and proper person to act in that capacity.

In determining whether a particular individual is a fit and proper person to act as a VAT representative for an NETP, the Department will use the following criteria.

A person may not be accepted to act as a VAT representative for an NETP if they

  • have been disqualified as a Director under Company Law
  • are, or have been involved, in crime and/or have relevant criminal convictions
  • have had previous requests for a similar role in VAT or any other regime revoked or refused
  • have personally received penalties for deliberate wrongdoing
  • have any connection with the business they wish to represent, or with key persons involved in that business, or with any non-compliant or fraudulent businesses
  • have fraudulent trading history
  • hold no assets and have no insurance
  • have not fulfilled their own tax responsibilities, for example not paying their own VAT liabilities or not submitting their personal tax returns
  • have outstanding, unmanaged HMRC debts or a history of poor payment
  • submit or have previously submitted, an application that is inaccurate and incomplete and is an attempt to deceive, for example the hijacking of another person’s name
  • are bankrupt or in a IVA (Individual Voluntary Arrangement). 

This list is not exhaustive. 

Where you consider that the appointed VAT representative is not a fit and proper person, you may refuse to register them as a VAT representative, or cancel their registration as a VAT representative.  Where the NETP is under a direction to appoint a VAT representative, you should instruct them to appoint somebody else who meets the ‘fit and proper’ criteria.