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HMRC internal manual

Compliance Handbook

Charging penalties: suspending penalties: dealing with a lack of agreement to the conditions

If you are unable to get the person’s agreement to some or all of the suspension conditions you intend to set, you should consider, in conjunction with your manager, whether or not the taxpayer is likely to comply with the conditions if you impose them.

If that is unlikely then you should not suspend the penalty.

If the taxpayer says that they will comply with the condition or conditions even though they do not agree, you should suspend the penalty without agreement after obtaining authorisation.

You must notify the taxpayer of the suspension conditions using the NPPS100 and NPPS100(S), see CH405260.