ECSH44405 - Temporary sites and businesses that accept cash on delivery

Identifying temporary sites

In the course of dealing with an application you may identify that the business appears to be operating from a premises that it has not included in its registration. This address may be a temporary site.

This may be identified through: 

  • open-source checks e.g. looking at business website, or on receipt of information from the business 
  • contact from the business to query whether a temporary site needs to be included to its registration. 

Caseworker action

Where additional premises are identified, you should contact the business to advise that these addresses may need to be included in its registration. You can either contact the business by issuing a secure communication to its government gateway account or via email  and advise it to: 

  • include the additional premises in its registration or, 
  • present it with an opportunity to advise why it does not think that the additional premises should be registered.  

Where the business contacts HMRC to query whether an existing trading outlet needs to be included in its registration details, you should refer the business to the guidance in ECSH44125 and ask it to confirm that this address meets all of the conditions for a temporary site to be excluded from registration. 

Where the business confirms that all the conditions set out in ECSH44125 are met, you should inform the business that the existing trading outlet does not need to be added to its registration at this time, based on the information it has provided.  

Where the business confirms that some, but not all, of the exclusion conditions are met for the existing trading outlet to be considered a temporary site, you should inform the business that it is required to add this as an additional premises to its registration and pay the relevant fee.

If the business disagrees

If the business does not agree that the additional premises needs to be added to its registration, you should consider contacting the business to request that it provides further clarification of the management control, staffing, recording keeping and anti-money laundering systems that are in place at the existing trading outlet.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Cash on delivery

Businesses that accept cash on delivery are to be treated in the same way as businesses that trade through temporary sites as above. There is no requirement to include customers’ premises on their registration simply because that’s where the cash is received.