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HMRC Registration of Alcohol Wholesalers Scheme

HMRC previously published detailed proposals regarding the Alcohol Wholesalers Registration Scheme to be introduced in the Finance Bill 2015. The main purpose of this legislation is to tackle alcohol duty fraud.

All businesses buying and selling alcoholic drinks for wholesale will be affected, whether new or existing businesses in this trade sector.

These measures came into effect from October 2015. Alcohol wholesalers will be required to demonstrate that:

  1. They fulfil certain ‘fit and proper’ criteria
  2. They comply with new record keeping obligations
  3. They operate appropriate due diligence to avoid inadvertent involvement in the illicit alcohol market;
  4. They will only purchase alcohol from other registered wholesalers through checks conducted upon HMRC’s online register of approved alcohol wholesalers.

Wholesalers who are found either to be trading without having applied for registration before 1st January 2016 or to be trading beyond the conditions of their approval, will be liable to a penalty. 

Penalties for contravention of the scheme will vary from £3,000 to £10,000 fine per transaction. HMRC may also make a Director, Manager or Secretary personally liable for the penalty.

Alcohol retailers who purchase alcohol from wholesalers will also be affected by this scheme and will be expected to comply with stricter due diligence requirements.

Cartwright King is a national firm with expertise in dealing with issues involving HMRC. For more information please contact Sundeep Soor, Head of Tax & Fraud, on 07973 148738 or email

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