VCP11281 - Unauthorised issue penalty: Reconsiderations and Appeals: Formal appeal

Please note: the S 67 VATA 1994 penalty has been replaced by the VAT and Excise Wrongdoing penalty introduced by Schedule 41 Finance Act 2008. The VAT and Excise Wrongdoing penalty applies where a person makes an unauthorised issue of an invoice on or after 01/04/2010. If an unauthorised invoice has been issued before 01/04/2010 the S 67 penalty will continue to apply.

Please see the Compliance Handbook CH90000 Penalties for more information about the VAT and Excise Wrongdoing penalty. 

If you receive a formal appeal against a penalty for unauthorised issue of tax invoices, you must ensure that HMRC action has been correct in law before proceeding to Tribunal.