VATAC4400 | Using the discretion to direct stagger - addressing stagger manipulation, suspected missing trader VAT fraud cases and cases where financial difficulty could result in accumulating VAT debt: handling cases - general approach
From HM Revenue & Customs · VAT Accounting Manual
HMRC’s decision-making process will be closely inspected in any Judicial Review to ensure it is reasonable and proportionate to the mischief we are seeking to prevent. When making a decision to direct, you must:
look at each case on its own merits;
take all relevant factors into account; and
not take account of irrelevant factors
weigh the impact on any abuse with the impact of our decision on the business.
in cases involving financial difficulty contact Debt Managment to agree the proposed action.