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HMRC internal manual

Compliance Handbook

Penalties for Failure to Notify: Appeals against a penalty: Who is entitled to appeal

In normal circumstances the penalty is assessed on a person and any appeal and review rights are restricted to that person.

Where a penalty is payable by a company for a deliberate failure to notify

  • which was attributable to an officer of the company, and
  • we pursue the officer for a portion of the penalty,

that officer will have the same appeal and review rights as a person would have in respect of that portion, see CH75520 for more details.

Appeals may be made and reviews requested by agents on behalf of their clients.