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 Tax Administration, Litigation and Advice (TALA) 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.