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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
, see all updates

Charging Penalties: establishing penalty behaviour: evaluating evidence: evidence of a non-deliberate failure or VAT or excise wrongdoing

All failures to notify and VAT or excise wrongdoing create a liability to a penalty unless there is a reasonable excuse, see CH402708.

Non-deliberate penalties should be charged if you are not able to obtain sufficient evidence to establish deliberate behaviour.

Further guidance on and examples of non-deliberate behaviour are in the technical guidance at

  • for failure to notify, see CH72000 
  • for wrongdoing, see CH93000.

Note: Further penalties at 12 months for non-deliberate failures to file certain returns on time are charged automatically and do not require any input into NPPS. Penalties for late filing of self-assessment returns are charged in the Computerised Environment for Self Assessment (CESA). Penalties for late filing of CIS300 returns are charged in Construction Industry Scheme Reform (CISR).