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Official guidance
VAT Civil Penalties

VCP10430 · Belated Notification Penalty: Reasonable excuse

  • VCP10431 · Legal provisions for reasonable excuse
  • VCP10432 · What you should take into account
  • VCP10433 · Trader states there have been postal difficulties
  • VCP10434 · Trader states form requested but not sent
  • VCP10435 · Postal difficulties HMRC record keeping
  • VCP10436 · Compassionate circumstances
  • VCP10437 · Ignorance of the law
  • VCP10438 · Turnover calculations and limits
  • VCP10439 · Subcontractor payments not included in turnover
  • VCP10440 · Status of taxable supplies misunderstood
  • VCP10441 · Reliance on a third party
  • VCP10442 · Miscellaneous reasonable excuse claims
  1. Belated Notification Penalty: Reasonable excuse: contents
  2. Belated Notification Penalty: Reasonable excuse: Reliance on a third party

VCP10441 | Belated Notification Penalty: Reasonable excuse: Reliance on a third party

From HM Revenue & Customs · VAT Civil Penalties

Please see the Compliance Handbook CH70000 for more details about the new failure to notify penalty.

Reliance on a third party is specifically excluded as a reasonable excuse in the VAT Act 1994, Section 71

This has been confirmed in several tribunal cases. The third party is usually an accountant but can be any person. Reliance on the third party to perform a task or any slowness or inaccuracy on the part of the third party cannot be accepted as reasonable excuse

However, in circumstances where the third party becomes ill and cannot perform their duties at the proper time, reasonable excuse may be allowable for a limited period, see VCP10436.

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