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Official guidance
VAT Fulfilment House Due Diligence Scheme

FHDDS32000 · Approval, revoking the approval and variations: approval – process

  • FHDDS32100 · Approval, revoking the approval and variations: approval - process: overview
  • FHDDS32110 · Approval, revoking the approval and variations: approval – Large Business and WMBC applications
  • FHDDS32120 · Approval, revoking the approval and variations: approval – Initial actions and checks
  • FHDDS32200 · Approval, revoking the approval and variations: approval – Fit and proper test
  • FHDDS32320 · Approval, revoking the approval and variations: approval – pre-approval visit
  • FHDDS32360 · Approval, revoking the approval and variations: approval – Deciding whether to grant or reject approval
  • FHDDS32380 · Approval, revoking the approval and variations: approval – Granting the approval with additional conditions/restrictions
  • FHDDS32390 · Approval, revoking the approval and variations: approval – Recording and notifying a decision to grant an approval with conditions
  • FHDDS32400 · Approval, revoking the approval and variations: approval – Rejecting an application: minded to reject
  • FHDDS32410 · Approval, revoking the approval and variations: approval – Rejecting an application for approval
  • FHDDS32420 · Approval, revoking the approval and variations: approval – Notifying a decision to reject an approval
  1. Approval, revoking the approval and variations: approval – process: contents
  2. Approval, revoking the approval and variations: approval – Deciding whether to grant or reject approval

FHDDS32360 | Approval, revoking the approval and variations: approval – Deciding whether to grant or reject approval

From HM Revenue & Customs · VAT Fulfilment House Due Diligence Scheme

Once you have completed the pre-approval activity, and received any further information that you have requested, a decision must be made either to approve or reject the application.

It is vital that the decision made is fully substantiated by your findings. You must ensure you have evidence to support your decision; generalities, hearsay or gut feelings will not suffice.
As the assurance officer you are the ‘decision maker’ in terms of granting or rejecting approval and are responsible for inputting the decision on to RCM.

Meeting the ‘fit and proper’ standards is required by law and you should reject the application if any of the criteria are not met.
In addition to fit and proper, your pre-approval activity will have involved confirming that the applicant is aware of the obligations when approved under the scheme and you will have discussed what preparations are being made.

Note: Before 1st April 2019, it was not to be expected that the applicant would have due diligence or record keeping processes in place at the time of application as these are not required by law until 1st April 2019 and therefore you should not have rejected an application on those grounds.

If after consideration of all the evidence you deem it appropriate you should grant the approval.

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