Commentary

A4.593 Penalty negotiations

Administration and compliance

A4.593 Penalty negotiations

Penalty assessments and appeals

A4.593 Penalty negotiations

Unless the penalty is fixed there is usually scope for negotiation over the penalty, if any, to be imposed in a particular situation. Representations should be made during the time the officer is investigating the question of a penalty.

Before any penalty is actually imposed, HMRC should provide a written explanation about the penalty position and provide a reasonable opportunity to the taxpayer to respond before, and if, a penalty is finally issued. Officers will be called to account for the way they progress an inquiry and they therefore cannot concede matters just

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