VATF12100 - Obtaining assistance and further guidance: VAT Serious Non-Compliance & Fraud Team (Indirect Tax Directorate)
Source: gov.uk (2025-04-24)


The VAT Serious Non-Compliance & Fraud Team is part of the Indirect Tax Directorate and has responsibility for:
- policy and legislation for civil interventions and litigation to counter VAT fraud, including the reverse charge for specified goods and services (VATF44200 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf44200));
- the Kittel (VATF50000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf50000)) and Ablessio (VATF44500 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf44500)) principles, including formulation and guidance;
- all VAT fraud civil litigation (VATF90000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf90000));
- Joint and Several Liability (VATF44100 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf44100)), including drafting and publishing Notice 726 (https://www.gov.uk/government/publications/vat-notice-726-joint-and-several-liability-for-unpaid-vat) Joint and several liability for unpaid VAT and associated policy guidance (the JSL Guidance Manual (https://www.gov.uk/hmrc-internal-manuals/vat-joint-and-several-liability/jsl))
- the policy on ‘Input Tax deduction without a valid VAT invoice’ Statement of Practice (http://www.hmrc.gov.uk/briefs/vat/brief8309.htm) (VATF42500 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf42500));
- advising on the policy aspects of judicial reviews and other civil litigation involving VAT fraud, including tort of conspiracy (VATF90000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf90000));
- providing advice to Specialist Investigations, Local Compliance and Large Business Services compliance staff on when and how to use a VAT civil intervention (VATF80000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf80000));
- monitoring and advising on new variants of VAT fraud (VATF88000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf88000)); and
- monitoring and advising on VAT fraud in relation to VAT policy or legislative changes, or new processes.
Advice from the VAT Serious Non-Compliance & Fraud Team can be sought at any point during your investigations into the taxable person’s credibility, even if you have not quantified any inaccuracy or tax at risk. You can also contact the team prior to the case being submitted under the evasion referral process (VATF84000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf84000)), although please be aware that the team is not an alternative to the evasion referral process, which must be followed if the case meets the criteria.

Unless you are making a formal submission (VATF85000 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf85000)) or require formal advice you are free to contact members of the team by email or telephone. If you are going to use one of these methods please ensure that you have all the details to hand in order to provide as much information as possible.

(Please note that the Indriect Tax Directorate £150,000 tax at risk limit does not apply to fraud cases.)

The VAT Serious Non-Compliance & Fraud Team is not responsible for the following:
- HMRC’s criminal investigation policy
- Civil Investigation of fraud policy including COP9
- Civil Investigation of evasion under PN160, PN161 and PN300 and
- HMRC forfeiture policy under PN12A (Seizure and Restoration)
HMRC’s penalties regime (VATF44300 (https://www.gov.uk/hmrc-internal-manuals/vat-fraud/vatf44300))
- For technical queries: Tax Administration Litigation and Advice (TALA)