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HMRC internal manual

Compliance Handbook

Penalties for Failure to Notify: How to process a penalty: What the assessment must include

You must include the following on the penalty assessment

  • the date of the assessment
  • the legislation under which the penalty is due
  • the amount of potential lost revenue (PLR)
  • your view of the person’s behaviour
  • the reduction for disclosure
  • the amount of the penalty
  • the period to which the penalty relates, see CH71200.

Remember that for the purpose of most taxes, duties or levies, a partnership is treated as a person in its own right and if the penalty assessment relates to those taxes, duties or levies, it should be issued to the partnership.

For income tax, capital gains tax and corporation tax, a partnership does not have a liability. The liability is shared amongst the relevant partners for the tax period involved.