Penalties for submitting a VAT Return on paper instead of online

Virtually all VAT-registered businesses are legally required to submit their VAT Returns online and pay any VAT due electronically, apart from a very small number that are exempt.

This guide explains the circumstances in which HM Revenue & Customs (HMRC) will charge a penalty if you submit a paper return when you are required to submit your return online.

On this page:

When you must submit your VAT Returns online

Virtually all VAT-registered businesses, apart from a very small number of exemptions, have to submit their VAT Returns online and pay any VAT due electronically.

Read more about moving from paper to online VAT Returns

Read about exemptions from doing your VAT online

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When HMRC will charge a penalty

If you were required to submit your returns online from 1 April 2010 or were registered for VAT on or after that date, you will be charged a penalty if you submit a paper return for accounting periods ending on or after 31 March 2011.

If you were required to submit your returns online from 1 April 2012, you will be charged a penalty if you submit a paper return in respect of a period ending on or after 31 March 2013.

HMRC may also charge separate penalties if you pay late or make an error on your return.

Read more about penalties for mistakes and delays with your VAT

Amount of the penalty

The amount of each penalty will depend on your annual turnover (excluding VAT). The calculation of your turnover is based on the 12 months’ figures up to, and including those on the paper return which triggers the penalty. The table below shows the different amounts of penalty.

Annual VAT-exclusive turnover Penalty
£22,800,001 and above £400
£5,600,001 to £22,800,000 £300
£100,001 to £5,600,000 £200
£100,000 and under £100

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How to pay a penalty

If HMRC charge you a penalty they will tell you in writing how you can pay it.

For more information on ways you can make payments to HMRC follow the link below.

How to pay a penalty for submitting a paper VAT Return

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What to do if you disagree with a penalty HMRC has charged

If you disagree with a penalty HMRC has charged for submitting a paper VAT Return you can:

  • ask for HMRC’s decision to charge you a penalty to be reviewed by an HMRC officer not previously involved in the matter
  • appeal to an independent tribunal

You can ask for a penalty to be reviewed if any of the following apply:

  • you have submitted your VAT Return online
  • you are not required to submit your VAT Return online
  • the amount of penalty charged is wrong
  • you have a reasonable excuse for not submitting your VAT Return online

A reasonable excuse is normally an unexpected or unusual event, either unforeseeable or beyond your control, which prevents you from submitting your return online. Relying on someone else to submit the return on your behalf does not count as a reasonable excuse. Each case will be considered on its own facts.

If you want a penalty to be reviewed, write to:

HM Revenue & Customs
Appeals Unit - VAT Online
Crownhill Court
Tailyour Road
Crownhill
Plymouth
PL6 5BZ

You should write within 30 days of the date on the penalty notification letter, give your reasons why you do not agree with the penalty and enclose any information you think is relevant. HMRC will not try to collect the penalty while the review is carried out.

If you want to appeal to an independent tribunal, you should do so within 30 days of the date of the penalty or HMRC’s decision to uphold a decision following review.

If you opt for a review, you can still appeal to the tribunal after the review has finished.

Find out more about appeals and reviews

Find out more about tribunals on the HM Courts & Tribunals Service website (Opens new window)

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