Section 48(5)

A VAT representative shall not by virtue of subsection (3) above be guilty of any offence except in so far as— the VAT representative has consented to, or connived in, the commission of the offence by his principal; the commission of the offence by his principal is attributable to any neglect on the part of the VAT representative; or the offence consists in a contravention by the VAT representative of an obligation which, by virtue of that subsection, is imposed both on the VAT representative and on his principal.

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Source: legislation.gov.uk · retrieved 2026-07-28