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HMRC internal manual

Compliance Handbook

Charging penalties: appeals: considering all appeals together

Wherever possible, the tribunal wants to consider appeals against all assessments issued during a compliance check at the same time. This includes assessments issued to recover lost tax as well as penalty assessments. Persons should not be put to the expense of two tribunal hearings when all related appeals can be considered at one hearing.

It is the practice of the Local Compliance Appeals & Review Unit, where appropriate, to consider appeals against tax and penalty assessments at the same time.

You should issue penalty assessments when tax assessments are issued or at the earliest opportunity. This is legally correct and good customer service. It can reduce the need for repeated reviews and tribunal hearings about differing issues within the same compliance check.

What this means in practice is that the person should know how much to pay when a check is completed.