HMRC regard the following as high-risk:

(a)persons connected with past failures to pay VAT due;

(b)persons who fail to comply with their VAT obligations in their current VAT-registered business, in particular the requirement to submit returns and pay VAT on time; and

(c)businesses run by persons convicted for VAT fraud or by ‘shadow’ directors, i.e. undischarged bankrupts or persons otherwise disqualified from acting as a director (www.gov.uk/government/publications/securities-in-respect-of-vat-at-risk).

HMRC may send or give a notice of requirement to a taxable person if:

in their previous or current business, they have failed to comply with their VAT obligations;

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