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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Penalties: Other penalty issues: Double jeopardy

This page applies for notices issued

  • on or after 1 April 2009 under FA08/Sch36, or
  • on or after 1 April 2011 under CEMA79/S118

and for inspections carried out under FA08/Sch36 on or after 1 April 2009.

We cannot charge an initial, daily or tax-related penalty for failing to comply with

  • an information notice or an excise information notice under CEMA79/S118BA, or
  • deliberately obstructing an inspection

if the person has been convicted of a criminal offence, see CH27200, in respect of the failure or obstruction.