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HMRC internal manual

VAT Small and Medium Enterprises Assurance Manual

HM Revenue & Customs
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Check on business activities: rulings, decisions for example

  • your pre-visit preparation should inform you of any changes in liability or regulations that may have affected rulings previously given. You should check that the trader is aware of these changes and has put them into practice;
  • the trader’s compliance with previous rulings for example, and their relevance to the trader’s business, need not be reviewed during the basic checks but should be borne in mind for action later in the audit; and
  • new decisions must be confirmed in writing and captured to EF.

incorrect liability rulings or assessments can have serious and expensive consequences for the Department. Such costs could arise from tax written off or remitted, and those claimed from the Department by financial advisors acting for their clients. It is important to take appropriate action to assure such decisions before they reach the traders and to have in place a system for checking/approving those decisions which the potential for serious financial consequences.

Therefore all written liability rulings and assessments where there is reason to believe that the tax at risk exceeds £50k for a one off issue, or £25k per year for on-going issues should be checked, and recorded, by an experienced named colleague before dispatch. That colleague should preferably hold the VLTT qualification.