I have a client who, we now find, should have registered for VAT back in 2011. He has never been self-employed before, was ignorant of the rules and simply did not realise he had to register.
He now wishes to bring himself up to date but has no available funds. He expects to recover the VAT from his clients but we realise there could be substantial penalties, interest etc on top.
I am suggesting he register immediately and explain the whole situation to HMRC, asking for a time to pay arrangement, but do I need to submit a SAR to NCA in the interim?
This is understandably a very worrying situation for all involved.
Thanks for any answers.