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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Charging penalties: suspending penalties: setting suspension conditions: specific conditions: SMART examples: introduction

Suspension conditions, must, if met, result in improvements to records or systems which would prevent future careless inaccuracies from occurring. All specific conditions must be SMART as detailed at CH83153.

The guidance at CH405179 onwards provides

  • examples where the suspension conditions set would not meet this criteria, and
  • how the conditions can be improved to ensure they are SMART.

The examples are provided in the following format

  • How the inaccuracy arose?
  • Specific conditions set - ‘SMART’ criteria not met.
  • How to make the specific conditions SMART?
  • Methods of checking the suspended conditions to ensure they have been met.

SMART criteria should usually involve implementing of, or changes to, systems and processes. When setting the SMART conditions you should make it clear to the person that they should be able to provide evidence, at the end of the suspension period, which satisfies us that processes have been put in place to ensure that the inaccuracy will not occur again.

Evidence can be anything from copies of the correspondence, emails, outputs, control sheets, changes to the company paperwork and change and enhancement to the computer system. (If the evidence is IT based, a visit may be required to see how the new system is working).

The above is not an inclusive list, there may be other checks you need to carry out depending on the suspension conditions you had set and agreed.