HMRA4010 – Refusal/cancellation: When can we refuse an application for approval, registration, or licence?

Where we have the discretion, any decision to refuse (or cancel) must be based on a solid foundation of evidence that satisfactorily supports the decision at a Tribunal hearing. Your evidence must show that, on the balance of probability, the trader is not a ‘fit and proper’ person to hold the warehouse, distillery or REDS based approval/licence/registration, that there is, or would be, a significant risk to the revenue, or that any of the requirements stated within this guidance have not been satisfactorily met within the trader’s application. Your decision should be based on the suitability of the business and its key officials. The credibility of the business should be considered a factor in the decision.

Where grounds for refusal or cancellation are identified, the officer should discuss the detail with his line manager before escalating the matter to the appropriate registration team.