FHDDS51420 - Penalties, sanctions and offences: penalties – policy: Trading without approval - deliberate and concealed

Trading without approval is deliberate and concealed if the person:

• knows that they are required to be registered

• fails to seek approval at the correct time, and

• takes active steps to conceal the fact that they are required to be registered.

The burden will be on HMRC to show that concealment arrangements were made. The act of concealment may include:

• destroying or concealing records which show evidence of trading as an imported goods fulfilment business

• concealing the use of premises used to carry on an imported goods fulfilment business.

• misrepresenting the nature of the company’s business activities to give a false impression that their activities do not conform to the definition of an imported goods fulfilment business, such as for example disguising the true ownership of the goods being handled by the business, or disguising the fact that the goods were imported.