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HMRC internal manual

VAT Traders’ Records Manual

How to treat requests for a concession: Introduction

Further information on the availability of concessions is set out in Notice 700 The VAT Guide section 19.2 and Notice 700/21 Keeping VAT Records. You should view a request for a concession sympathetically, but you should not grant it automatically. In granting a concession, you should allow the minimum period of preservation in line with a trader’s commercial practice that is consistent with effective assurance. The recommended minimum periods of preservation for certain types of record are set out in VATREC3032.

Other factors that you should take into account when considering a request for a concession include:

  • Is the granting of a concession likely to create serious assurance difficulties?
  • Is there reason to doubt the trader’s revenue character? What is the trader’s reliability indicator and record of under-declarations? Has the trader been subject to a misdeclaration penalty?
  • What degree of independent audit assurance is imposed?
  • Would insistence on preservation of records for the maximum period create real storage problems for the trader and/or involve undue extra expense?
  • Is the trader aware that, without concession, records may be preserved on microfilm, microfiche or by electronic means in line with Notice 700 section19.

If you do grant a concession, you should confirm it in writing and keep a copy of the letter in the EF record on a permanent basis.