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HMRC internal manual

Alcohol Wholesaler Registration Scheme

HM Revenue & Customs
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Special reduction: reviews and penalty appeals

A person may ask for a review of the penalty and special reduction may be considered as part of the review.

If it is considered likely that a submission to TAA may be required it would be appropriate to negotiate an extension to the review period at an early stage.

A person cannot appeal directly against our decision not to allow a special reduction, but they can appeal against the amount of the penalty we impose.

A tribunal may:

  • either affirm HMRC’s decision on special reduction (but possibly apply the same percentage reduction to a different starting point)
  • or substitute their decision on special reduction for HMRC’s decision, but only if the tribunal considers that HMRC’s decision was flawed, see CH64600.