WOWGR Application Or Refusal

Danielle Chapman

Danielle Chapman, Altion Law

Altion Law has supported many companies in WOWGR applications, WOWGR revocations and in having WOWGR conditions removed. Any business can apply for a WOWGR and the initial online process appears very simple.

Be aware that once a request has been made there will be a following request for information that HMRC will require. It is normal to be given 14 days to provide all this information and therefore businesses should not apply for the WOWGR until they have prepared at a minimum:

  • A Business Plan, including evidence of a commercial need for a WOWGR
  • Details of trading partners and due diligence on these partners
  • Types of products that will be traded
  • Clear evidence on who will be undertaking the movements
  • Cash flows
  • Insurances
  • Published Accounts
  • Profit and losses

Once these have been provided an officer will review your plan with you, in depth and will also undertake background checks on your history both personally and via any associated entities. HMRC will apply the Fit and Proper test to assess the risk to the Exchequer of granting a WOWGR to your business. Additional information is often required to be provided after the meeting.

The length of time the application will take depends upon the risk a party poses to the Exchequer. HMRC state they aim for a 45 day decision window but realistically businesses should allow several months for this process to take place.

A WOWGR Success Application

Altion Law worked with a specialist Wine and Spirits importer to secure a WOWGR licence for them to hold the goods in duty suspension. The company had previously been paying the duty on import but due to growth this was now a concern for cash flow.

Altion Law worked with the company and produced a business plan, due diligence and other associated documents to support the application. With the work that had been done the client was confident enough to attend the WOWGR application meeting with HMRC on their own and were approved within days.


What Are The Risks For WOWGR Holders? And How This Impacts Bonds And Movement Guarantee Hauliers.

What is often not appreciated by those applying for a WOWGR is the liability should goods be involved in fraud or seized. If HMRC are not satisfied that the goods arrived at the destination, HMRC can raise assessments for unpaid excise duty. Additionally if the goods are seized, this creates a duty point and assessments will be raised against either the WOWGR trader, the haulier or the bond and in some cases joint assessments.

Additionally if HMRC have cause to believe there are multiple occurrences of non-duty payment or VAT fraud, HMRC will raise assessments for excise duty and VAT on a number of the movements or in some cases all the movements undertaken by a business in that trading relationship. These penalties can also be applied both to the company and to the Directors personally.

It is important to seek legal advice at the earliest opportunity should HMRC raise concerns about the validity of a supply chain. As a WOWGR is issued with consideration for the fit and proper test, any issues of non compliance can lead to a WOWGR being revoked and additionally this can affect other licences/approvals such as Movement Guarantee’s and AWRS numbers.


Make An Enquiry Today

Altion Law can assist you if you are applying for a WOWGR for your existing or for a future business opportunity. If you would like to have a confidential discussion with a member of our team, please either complete an Online Enquiry or call us on 01908 414990 and we will be pleased to help you.

“Professional and honest service who certainly know their business. Kept informed all of the time and it was smooth successful process”.