We’ve already commented in past posts on HMRC’s interest in the low level of registrations they have received for the new Plastic Packaging Tax (PPT). Today we’ve sight of a new Public Guidance Note that has been issued on the risk for organisations that may be seen as liable for unpaid PPT as a result of the omissions of their own suppliers, rather than their own.
The guidance suggests, but does not prescribe, the type of due diligence checks that organisations involved in the following may look to undertake to protect themselves from the risk of assessments from HMRC for unpaid PPT within their supply chain. The note states:
“We can issue a secondary liability assessment notice if you have been carrying out activities as part of a related business and either:
- taken steps along with the person with primary liability to not pay the tax
- been involved in one of the following:
- transporting chargeable plastic packaging components (for example, a haulier)
- storing chargeable plastic packaging components (for example, a warehouse owner or operator)
- dealing in chargeable plastic packaging components (for example, a supplier or retailer)”
Organisations that have colluded to avoid paying PPT are top of the risk list but the broadening of the supply chain net to cover hauliers; warehouse owners/operators and retailers seem to demonstrate the keenness of HMRC to ensure the long-held role of taxpayers to be “unpaid tax collectors” for VAT purposes to be extended to all taxes. We need to “police” the tax down as well as up our supply chains, it appears.
An unwelcome compliance cost for businesses to add management time to this area but, clearly, HMRC feels that current receipts from PPT aren’t what they were expecting and are broadening the liability net to encourage compliance.
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