CH178330 - Sanctionable conduct by tax advisers: penalty for sanctionable conduct: special reduction
When we are assessing a penalty for sanctionable conduct, we may use our discretion to reduce the penalty because of special circumstances. This is called a special reduction.
Special circumstances do not include:
- The tax advisers’ ability to pay any penalty, or
- The fact that a loss of tax revenue from a client is balanced by an overpayment by another person (whether a client or not).
We may also use our discretion to stay the penalty or agree a compromise in relation to proceedings for the penalty.
All the guidance on special reduction for all relevant taxes is in a separate chapter, see CH170000.
FA12/SCH38/PARA27 as amended