Tag Archives: penalties

VAT – What is Reasonable Care?

By   12 April 2018
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What is reasonable care and why is it so important for VAT?

HMRC state that “Everyone has a responsibility to take reasonable care over their tax affairs. This means doing everything you can to make sure the tax returns and other documents you send to HMRC are accurate.”

If a taxpayer does not take reasonable care HMRC will charge penalties for inaccuracies.

Penalties for inaccuracies 

HMRC will charge a penalty if a business submits a return or other document with an inaccuracy that was either as a result of not taking reasonable care, or deliberate, and it results in one of the following:

  • an understatement of a person’s liability to VAT
  • a false or inflated claim to repayment of VAT

The penalty amount will depend on the reasons for the inaccuracy and the amount of tax due (or repayable) as a result of correcting the inaccuracy.

How HMRC determine what reasonable care is

HMRC will take a taxpayer’s individual circumstances into account when considering whether they have taken reasonable care. Therefore, there is a difference between what is expected from a small sole trader and a multi-national company with an in-house tax team.

The law defines ‘careless’ as a failure to take reasonable care. The Courts are agreed that reasonable care can best be defined as the behaviour which is that of a prudent and reasonable person in the position of the person in question.

There is no issue of whether or not a business knew about the inaccuracy when the return was submitted. If it did, that would be deliberate and a different penalty regime would apply, see here  It is a question of HMRC examining what the business did, or failed to do, and asking whether a prudent and reasonable person would have done that or failed to do that in those circumstances.

Repeated inaccuracies

HMRC consider that repeated inaccuracies may form part of a pattern of behaviour which suggests a lack of care by a business in developing adequate systems for the recording of transactions or preparing VAT returns.

How to make sure you take reasonable care

HMRC expects a business to keep VAT records that allow you to submit accurate VAT returns and other documents to them. Details of record keeping here

They also expect a business to ask HMRC or a tax adviser if it isn’t sure about anything. If a business took reasonable care to get things right but its return was still inaccurate, HMRC should not charge you a penalty. However, If a business did take reasonable care, it will need to demonstrate to HMRC how it did this when they talk to you about penalties.

Reasonable care if you use tax avoidance arrangements*

If a business has used tax avoidance arrangements that HMRC later defeat, they will presume that the business has not taken reasonable care for any inaccuracy in its VAT return or other documents that relate to the use of those arrangements. If the business used a tax adviser with the appropriate expertise, HMRC would normally consider this as having taken reasonable care (unless it’s classed as disqualified advice)

Where a return is sent to HMRC containing an inaccuracy arising from the use of avoidance arrangements the behaviour will always be presumed to be careless unless:

  • The inaccuracy was deliberate on the person’s part, or
  • The person satisfies HMRC or a Tribunal that they took reasonable care to avoid the inaccuracy

* Meaning of avoidance arrangements

Arrangements include any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable). So, whilst an arrangement could contain any combination of these things, a single agreement could also amount to an arrangement.  Arrangements are `avoidance arrangements’ if, having regard to all the circumstances, it would be reasonable to conclude that the obtaining of a tax advantage was the main purpose, or one of the main purposes of the arrangements.

NB: We at Marcus Ward Consultancy do not promote or advise on tax avoidance arrangements and we will not work with any business which seeks such advice.

Using a tax adviser

If a business uses a tax adviser, it remains that business’ responsibility to make sure it gives the adviser accurate and complete information. If it does not, and it sends HMRC a return that is inaccurate, it could be charged penalties and interest.

None of us are perfect

Finally, it is worth repeating a comment found in HMRC’s internal guidance “People do make mistakes. We do not expect perfection. We are simply seeking to establish whether the person has taken the care and attention that could be expected from a reasonable person taking reasonable care in similar circumstances…” 

VAT: Latest from the courts – option to tax, TOGC and deposits

By   26 March 2018
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Timing is everything

The First Tier Tribunal (FTT) case of Clark Hill Ltd (CHL) illustrates the detailed VAT considerations required when selling property. Not only are certain actions important, but so is timing.  If a business is one day late taking certain actions, a VAT free sale may turn into one that costs 20% more than anticipated. That is a large amount to fund and will obviously negatively affect cashflow and increase SDLT for the buyer, and may result in penalties for the seller.

The case considered three notoriously difficult areas of VAT, namely: the option to tax, transfers of going concerns and deposits.

Background

CHL owned four commercial properties which had opted to tax. CHL sold the freehold of these properties with the benefit of the existing leases. As a starting point VAT would be due on the sale because of the option.  However, the point at issue here was whether the conditions in Article 5 of the Value Added Tax (Special Provisions) Order 1995 were met so that the sale could be treated as a transfer of a business as a going concern (TOGC) and could therefore be treated as neither a supply of goods nor a supply of services for VAT purposes, ie; VAT free. The point applied to two of the four sales. The vendor initially charged VAT, but the purchasers considered that the TOGC provisions applied. CHL must have agreed and consequently did not charge VAT. HMRC disagreed with this approach and raised an assessment for output tax on the value of the sale.

TOGC

In order that a sale may qualify as a TOGC one of the conditions is that; the assets must be used by the transferee in carrying on the same kind of business, whether or not as part of any existing business, as that carried on by the transferor in relation to that part. It is accepted that in a property business transfer, if the vendor has opted to tax, the purchaser must also have opted by the “relevant date”.  If there is no option in place at that time HMRC do not regard it as “the same kind of business” and TOGC treatment does not apply.

Relevant date

If the purchaser opts to tax, but, say, one day after the relevant date, there can be no TOGC. The relevant date in these circumstances is the tax point. Details of tax points here

Basically put, a deposit can, in some circumstances, create a tax point. In this case, the purchaser had paid a deposit and, at some point before completion of the transfer of the property, the deposit had been received by the seller or the seller’s agent. The seller notified HMRC of the option to tax after a deposit had been received (in two of the relevant sales). The issue here then was whether a deposit created a tax point, or “relevant date” for the purposes of establishing whether the purchaser’s option to tax was in place by that date.

Decision

The judge decided that in respect of the two properties where the option to tax was not notified until after a deposit had been paid there could not be a TOGC (for completeness, for various other reasons, the other two sales could be treated as TOGCs) and VAT was due on the sale values. It was decided that the receipt of deposits in these cases created a relevant date.

Commentary

There is a distinction between opting to tax and notifying that option to HMRC which does not appear to have been argued here (there may be reasons for that). However, this case is a timely reminder that VAT must be considered on property transactions AND at the appropriate time. TOGC is an unique situation whereby the seller is reliant on the purchaser’s actions in order to apply the correct VAT treatment. This must be covered off in contracts, but even if it is, it could create significant complications and difficulties in obtaining the extra payment. It is also a reminder that VAT issues can arise when deposits are paid (in general) and/or in advance of an invoice being issued.

We recommend that VAT advice is always taken on property transactions ad at an early stage. Not only can situations similar to those in this case arise, but late consideration of VAT can often delay sales and can even cause such transactions to be aborted.

VAT: Fulfilment Businesses – HMRC announce new rules

By   12 March 2018
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The Fulfilment Businesses (Approval Scheme) Regulations 2018

New regulations come into place on 1 April 2019 which will affect fulfilment businesses (entities which carry out the process of taking an order and executing it by making it ready for delivery to its intended customer, usually involving warehouse pickup, packaging, labelling, etc).  These are known as The Fulfilment Businesses (Approval Scheme) Regulations 2018 and apply to businesses distributing goods to customers in the UK on behalf of suppliers based in countries outside the EU (third countries). The regulations set out that such businesses will be required to be approved by HMRC in order to carry on its activities. Voluntary registration will begin from 1 April 2018.

The rules cover:

  • how to register
  • how and when to make an application for approval
  • the obligations under the scheme (which include the requirement to carry out due diligence in respect of the third party suppliers and verifying a third country customer’s VAT registration number)
  • and, as always with VAT; the penalties for breaches of the regulations

The Finance (No. 2) Act 2017, section 49(1) provides that a person may not carry on a third country goods fulfilment business otherwise than in accordance with an approval given by the HMRC. A person carries on a third country goods fulfilment business if they meet the test set out in section 48 of the Finance (No. 2) Act 2017 . This test may be summarised as:

  • a person carries on a third country goods fulfilment business if the person, by way of business;
    • stores third country goods which are owned by a person who is not established in a Member State, or
    • stores third country goods on behalf of a person who is not established in a Member State,

at a time when the conditions below are met in relation to the goods.

The conditions are that:

  • there has been no supply of the goods in the United Kingdom for the purposes of VATA 1994, and
  • the goods are being offered for sale in the United Kingdom or elsewhere

Usually, but not always, these are goods purchased online. Goods are “third country” goods if they have been imported from a place outside the EU.

These regulations follow on from measures announced in 2016 which state that HMRC will direct certain representatives for overseas businesses to appoint a VAT representative with joint and several liability for online marketplaces. The measures enable HMRC to hold an online marketplace jointly and severally liable for the unpaid VAT of an overseas business that sells goods in the UK via that online marketplace.

These measures further strengthen HMRC’s hand in an area which they consider a substantial amount of VAT is lost to them.

Please contact us if these new rules affect you or your clients.

VAT: Making Tax Digital (MTD) New Regulations

By   5 March 2018
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The regulations for MTD have been published. These are known as The Value Added Tax (Amendment) Regulations 2018 and full details are available here

The Regulations set out that businesses to which the Regulations apply (see below) will be required to retain electronic records using functional compatible software and submit VAT returns via an Application Programming Interface (API) platform. HMRC has previously announced that acceptable software will include spreadsheets, but these will be required to be used in specific ways.

We are yet to see precise details of the relevant software and API platform, but it makes sense for VAT registered businesses to consider the implications of MTD and to plan for its introduction. 1 April 2109 seems a way off, but as always, it’s best not to wait until the last minute.  We expect more information in the coming months and we will endeavour to keep you up to date.

Background

MTD for VAT will come into effect from 1 April 2019. From that date, businesses with a turnover above the VAT threshold (currently £85,000) will have to:

  • keep their records digitally (for VAT purposes only), and;
  • provide their VAT return information to HMRC through MTD functional compatible software

What is compatible software?

The VAT Notice defines “functional compatible software” as “a software program or set of compatible software programs the functions of
which include—recording and preserving electronic records in an electronic form; providing to HMRC information from the electronic
records and returns in an electronic form and by using the API platform; and receiving information from HMRC using the API platform in
relation to a person’s compliance with obligations under these Regulations which are required to be met by use of the software”.

Submission to HMRC may be either through linking/bridging software or via API enabling the spreadsheets to access HMRC APIs and report data to HMRC systems.

What HMRC say about MTD

MTD was introduced with the following comments:

“The government recognises that the majority of businesses want to get their tax right, but the latest tax gap figures published by HMRC show that too many otherwise compliant businesses find this hard, even some who use an agent to help them. As a result over £8 billion a year in tax is lost from avoidable taxpayer errors.  This not only costs the public purse, it also causes businesses cost, uncertainty and worry when HMRC is forced to intervene to put things right.

HMRC wants to do more to help businesses get their tax right and MTD is a very important step in that direction. It will help businesses steer clear of avoidable errors, and give them a clearer view of their tax position in-year.

Businesses (including self-employed and landlords) will keep records of their income and expenditure digitally, and send summary updates quarterly to HMRC from their software (or app).

MTD will bring the tax system into line with what businesses and individuals now expect from other online service providers: a modern digital experience

MTD will help businesses get their tax and NICs right first time. That will reduce the likelihood of errors, giving businesses greater certainty

MTD is anticipated to take out around 10% of error on an ongoing basis, and give businesses a clearer view of their tax position in-year, enabling them to plan to meet their tax obligations at minimum cost and minimum disruption…”

 Please contact us if you have any queries or would like to discuss MTD.

UCC extension of time to implement systems

By   5 March 2018
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The Union Customs Code (UCC) is part of the modernisation of customs and serves as the new framework regulation on the rules and procedures for customs throughout the EU.

On 2 March 2018, the EC proposed that Customs authorities and economic operators be allowed to continue using already existing systems for the completion of certain customs formalities until 2025 at the latest. While most of the new or upgraded electronic systems that are necessary to apply the provisions of the UCC will be operational by 2020, some electronic systems may not be fully completed until 2025. Therefore this proposal would ensure that, in the case of the small number of customs formalities to be managed by the electronic systems that will not be completed by 2020, already existing electronic systems or paper-based procedures can continue to be used until the new systems are ready.

Full details of the latest proposals here

More on the background of how UCC affects UK importers and exporters here

VAT: Latest from the courts – Hastings Insurance Place Of Supply

By   22 February 2018
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In the First Tier Tribunal (FTT) case of Hastings Insurance the issue was where was the place of supply (POS) of services?

The POS rules determine under which VAT regime the supply is treated, whether the associated input tax may be recovered and how the services are reported. Consequently, determining the POS for any supply is vitally important because getting it wrong may not only mean that tax is overpaid in one country, but it is not declared in the appropriate country so that penalties and interest are levied. Getting it wrong also means that the input tax position is likely to be incorrect; meaning that VAT can be over or underclaimed.  The rules for the POS of services are notoriously complicated and even subtle differences in a business’ situation can produce a different VAT outcome.

Background

Hastings is an insurance services company operating in the UK.  The appeal relates to whether the appellant was able to recover input tax it incurred in the UK which was attributable to supplies of; broking, underwriting support and claims handling services made to a Gibraltar based insurance underwriter (Advantage) which supplied motor insurance to UK customers through Hastings. In order to obtain credit for the relevant input tax, the supply to Advantage must have a POS outside the EU, eg: the recipient had a place of belonging in Gibraltar and not the UK. HMRC argued that Advantage belonged in the UK so that the input tax could not have been properly recoverable.  Consequently, the issue was where Advantage “belonged” for VAT purposes.

The POS rules set out where a person “belongs”.

A taxable person belongs:

  • where it has a business establishment, or;
  • if different, where it has a fixed establishment, or;
  • if it has both a business establishment and a fixed establishment (or several such establishments), where the establishment is located which is most directly concerned with the supply

Further details on this point are explained here

Contentions

It was not disputed that Advantage had a business establishment in Gibraltar. The question was whether it also had a fixed establishment in the UK and, if so, whether the supplies of services were made to that fixed establishment rather than to its business establishment in Gibraltar. HMRC contended that Advantage had a fixed establishment in the UK which was “more directly concerned with the supply of insurance” such that the POS was the UK. This was on the basis that Advantage had human and technical resources in the UK which were actually used to provide its services to UK customers. Hastings obviously argued to the contrary; that Advantage had no UK fixed establishment and that services were supplied to, and by, Advantage in Gibraltar.

Technical

It may be helpful to look briefly at CJEU case law which considered what an establishment other than a business establishment is. It is: “characterised by a sufficient degree of permanence and a suitable structure in terms of human and technical resources”, where looking at the location of the recipient of the supply, “to enable it to receive and use the services supplied to it for its own needs” or, where looking at the location of the supplier, “to enable it to provide the services which it supplies”. 

Decision

The FTT concluded that the input tax in dispute is recoverable because it was attributable to supplies made to Advantage on the basis that it belonged outside the EU (as interpreted in accordance with the relevant EU rules and case law). After a long and exhaustive analysis of the facts the summary was;

  • The appellant’s human and technical resources, through which it provided the services to Advantage, did not comprise a fixed establishment of Advantage in the UK, whether for the purposes of determining where Advantage made supplies of insurance or where the appellant made the supplies of its services.
  • Even if, contrary to the FTT’s view, those resources comprised a fixed establishment in the UK, there is no reason to depart from the location of Advantage’s business establishment in Gibraltar as the place of belonging/supply in the circumstances of this case.

Summary

If this case affects you or your clients it will be rewarding to consider the details of the arrangements which are helpfully set out fully in the decision. This was, in my opinion, a borderline case which could have been decided differently quiet easily.  A significant amount of the evidence produced was deemed inadmissible; which is an interesting adjunct to the main issue in itself. Whether HMRC take this matter further remains to be seen.  It is always worthwhile reviewing a business’ POS in depth and we are able to assist with this.

VAT Error Disclosure under £10,000 – Draft Letter To HMRC

By   12 February 2018
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Error Correction – belt and braces

If an error is discovered on a past VAT return it is only usually necessary to report it to HMRC (on form VAT652) if it is £10,000 (net of all errors) or more of VAT.

However, because of the current penalty regime it is important to ensure that any adjustment qualifies as an unprompted disclosure. Consequently, we recommend that a letter similar to that below is sent to HMRC in cases where errors below £10,000 have been adjusted on a current return.

“RE: Letter of disclosure; error on return for period XXXX

 We disclose, (on behalf of our above named client), that the VAT return for the period XX/XX contained an inaccuracy.

 Reason, eg; Due to a processing error, three sales invoicing totalling……

 This resulted in the net VAT due for the period being understated by £XX

 As the error is within the limits for correction on the next VAT return, this error has been corrected on the return for the period in which the error was discovered, namely the period XX/XX.  No further action to correct the error is therefore necessary.

 Please treat this letter as an unprompted disclosure of an inaccuracy.  Alternatively, please advise me of any further details that you may require in order that that this letter may be treated as such.”

It is accepted that this course of action may prompt enquiries, but it is our view that that is preferable to having a potential ticking time bomb.

Please contact us should you have any queries on error disclosure.

VAT: Doctors and healthcare professionals

By   29 January 2018
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VAT and Doctors

I have noticed that I am receiving more and more queries in this area and HMRC does appear to be taking an increased interest in healthcare entities. This is hardly surprising as it can be complex and there are some big numbers involved.

(This article refers to doctors, but applies equally to most healthcare professional entities.)

The majority of the services provided by doctors’ practices are VAT free. Good news one would think; no need to charge VAT and no need to deal with VAT records, returns and inspections.

However, there is one often repeated question from practices; “How can we reclaim the VAT we are charged?”

The first point to make is that if a practice only makes exempt supplies (of medical services) it is not permitted to register for VAT and consequently cannot recover any input tax. Therefore we must look at the types of supplies that a practice may make that are taxable (at the standard or zero rate). If any of these supplies are made it is possible to VAT register regardless of the value of them. Of course, if taxable supplies are made, the value of which exceeds the current turnover limit of £85,000 in a rolling 12-month period, registration is mandatory.

Examples of services and goods which may be taxable are:

  • Drugs, medicines or appliances that are dispensed by doctors to patients for self-administration
  • Dispensing drugs against an NHS prescription (zero-rated)
  • Drugs dispensed against private prescriptions (standard-rated)
  • Medico legal services that are predominately legal rather than medical – for example negotiating on behalf of a client or appearing in court in the capacity of an advocate
  • Clinical trials or market research services for drug companies that do not involve the care or assessment of a patient
  • Paternity testing
  • Certain rental of rooms/spaces
  • Car parking
  • Signing passport applications
  • Providing professional witness evidence
  • Any services which are not in respect of; the protection, maintenance or restoration of health of a patient.

So what does VAT registration mean?

Once you join the “VAT Club” you will be required to file a VAT return on a monthly of quarterly basis. You may have to issue certain documentation to patients/organisations to whom you make VATable supplies. You may need to charge VAT at 20% on some services. You will be able to reclaim VAT charged to you on purchases and other expenditure subject to partial exemption rules (see below). You will have to keep records in a certain way and your accounting system needs to be able to process specific information.

Because doctors usually provide services which attract varying VAT treatment, a practice will be required to attribute VAT incurred on expenditure (input tax) to each of these categories. Generally speaking, only VAT incurred in respect of zero-rated and standard-rated services may be recovered. In addition, there will always be input tax which is not attributable to any specific service and is “overhead” eg; property costs, professional fees, telephones etc. There is a set way in which the recoverable portion of this VAT is calculated. VAT registered entities which make both taxable and exempt supplies are deemed “partly exempt” and must carry out calculations on every VAT return.

Partial Exemption

Once the calculations described above have been carried out, the resultant amount of input tax which relates to exempt supplies is compared to the de-minimis limits (broadly; £625 per month VAT and not more than 50% of all input tax). If the figure is below these limits, all VAT incurred is recoverable regardless of what activities the practice is involved in.

VAT registration in summary

Benefits

  • Recovery of input tax; the cost of which is not claimable in any other way
  • Potentially, recovery of VAT on items such as property, refurbishment and other expenditure that would have been unavailable prior to VAT registration
  • Only a small amount of VAT is likely to be chargeable by a practice
  • May provide opportunities for pre-registration VAT claims

Drawbacks

  • Increased administration, paperwork and staff time
  • Exposure to VAT penalties and interest
  • May require VAT to be added to some services provided which were hitherto VAT free
  • Likely that only an element of input tax is recoverable as a result of partial exemption
  • Uncertainty on the VAT position of certain services due to current EU cases
  • Potential increased costs to the practice in respect of professional fees.

Please contact us if any of the above affects you or your clients.

VAT: Disclosure of Avoidance Schemes – new rules

By   15 January 2018
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What needs to be disclosed, and by whom?

The Disclosure of Avoidance Schemes (VAT & Other Indirect Taxes) rules came into effect this month. HMRC Notice 799 sets out the new disclosure rules which are wider than the previous rules and now apply to all indirect taxes (ie; Insurance Premium Tax, General betting Duty, Pool Betting Duty, Remote Gaming Duty, Machine Games Duty, Gaming Duty, Lottery Duty, Bingo Duty, Air Passenger Duty, Hydrocarbon Oils Duty, Tobacco Products Duty, Duties on Spirits, Beer, Wine, Made-Wine and Cider, Soft Drinks Industry Levy, Aggregates Levy, Landfill Tax, Climate Change Levy and Customs Duties) – not just VAT.

The Notice contains information on what to do if a person promotes or uses arrangements (including any scheme, transaction or series of transactions) from 1 January 2018 that will, or are intended to, provide the user with a VAT or other indirect tax advantage when compared to adopting a different course of action.

The information includes:

  • What arrangements must be disclosed to HMRC
  • Who has responsibility to disclose notifiable proposals or arrangements to HMRC
  • Deciding who is a promoter of notifiable proposals or arrangements
  • Deciding who is an introducer of a notifiable proposal
  • What the obligations are as a promoter of notifiable proposals or arrangements
  • What the obligations are as an introducer of a notifiable proposal
  • What the obligations are as a user of notifiable arrangements including when there is a responsibility to disclose
  • How to make a disclosure to HMRC

It is crucially important to establish who is required to notify HMRC and of what. The rules do not just cover tax advisers but may also affect businesses directly.  

The effect of disclosure

A disclosure under the new rules has no effect on the tax position of any person who uses the arrangements. However, a disclosed arrangement may be challenged by HMRC or may be rendered ineffective by legislative action by Parliament.

Please contact us if you think any of the above affects you.

VAT – What records must be kept by a business?

By   9 January 2018
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Requirements for VAT records by taxable persons

I thought that it may be useful to round-up all the record-keeping requirements in one place and focus on what HMRC want to see. It is a good time to review record-keeping requirements as Making Tax Digital (MTD) is on the horizon. More on MTD in a later article.

General requirements

Every taxable person must keep such records as HMRC may require. Specifically, every taxable person must, for the purposes of accounting for VAT, keep the following records:

  • business and accounting records
  • VAT account
  • copies of all VAT invoices issued
  • VAT invoices received
  • certificates issued under provisions relating to fiscal or other warehouse regimes
  • documentation relating to acquisitions of any goods from other EC countries
  • copy documentation issued, and documentation received, relating to the transfer, dispatch or transport of goods by him to other EU countries
  • documentation relating to imports and exports
  • credit notes, debit notes and other documents which evidence an increase or decrease in consideration that are received, and copies of such documents issued
  • copy of any self-billing agreement to which the business is a party
  • where the business is the customer party to a self-billing agreement, the name, address and VAT registration number of each supplier with whom the business has entered into a self-billing agreement

Additionally

HMRC may supplement the above provisions by a Notice published by them for that purpose. They supplement the statutory requirements and have legal force.

Business records include, in addition to specific items listed above, orders and delivery notes, relevant business correspondence, purchases and sales books, cash books and other account books, records of daily takings such as till rolls, annual accounts, including trading and profit and loss accounts and bank statements and paying-in slips.

Unless the business mainly involves the supply of goods and services direct to the public and less detailed VAT invoices are issued, all VAT invoices must also be retained. Cash and carry wholesalers must keep all till rolls and product code lists.

Records must be kept of all taxable goods and services received or supplied in the course of business (standard and zero-rated), together with any exempt supplies, gifts or loans of goods, taxable self-supplies and any goods acquired or produced in the course of business which are put to private or other non-business use.

All records must be kept up to date and be in sufficient detail to allow calculation of VAT. They do not have to be kept in any set way but must be in a form which will enable HMRC officers to check easily the figures on the VAT return. Records must be readily available to HMRC officers on request. If a taxable person has more than one place of business, a list of all branches must be kept at the principal place of business.

Comprehensive records

In addition, we always advise businesses to retain full information of certain calculations such as; partial exemption, the Capital Goods Scheme, margin schemes, TOMS, business/non-business, mileage and subsistence claims, promotional schemes, vouchers, discounts, location of overseas customers, MOSS, and distance selling amongst other records. The aim is to ensure that any inspector is satisfied with the records and that any information required is readily available. This avoids delays, misunderstandings and unnecessary enquiries which may lead to assessments and penalties.

If you have any doubts that your business records are sufficient, please contact us.