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HMRC internal manual

Compliance Handbook

Special reduction: When to refer to TAA

You must submit the case to Tax Administration, Litigation and Advice (TALA) if your view is that special reduction may be applicable.

You may refuse to make a special reduction without submission to TALA but if you decide not to apply a special reduction and your refusal is disputed, then you must submit the case to TALA.

When you submit your case to TALA, you should give

  • a copy of the Penalty Decisions and Actions Checklist (PDAC) where the penalty was the result of a compliance check, see CH407100
  • full details of the facts upon which the request for a special reduction is based, and
  • your reasons for considering that a reduction is due or is not due.

You must not apply a special reduction without authority from TALA.