VPDS126020 | Vaping Products Duty and Vaping Duty Stamps: Uk representative for duty stamps: Fit and proper considerations: Key Persons

When considering whether a business should be approved under the VPPDSC Regulations, you must assess whether all identified key persons are fit and proper. This is essential to ensure that individuals who pose a serious threat to the revenue are not granted approval.

Key persons are individuals who play a significant role in the operation, control, or benefit of the business. They are considered part of the business’s “guiding minds”—those with authority or influence over decisions that affect compliance with revenue obligations.

Key persons may include:

• sole traders

• partners in a partnership

• company officials, such as:

  • directors

  • company secretaries

• significant beneficiaries, including those with substantial income or shareholding interests

• managers or other individuals identified during the assurance process who have the ability to influence decisions relevant to tax or excise compliance

If any key person fails to meet the fit and proper standard, this may be grounds to refuse or revoke approval, depending on the circumstances. Each case must be assessed on its own merits, taking into account the nature and influence of the individual’s role in the business.