Penalties for Inaccuracies: Other penalty issues: Interaction with other penalties and surcharges: Penalties charged on first and third parties for the same inaccuracy must not exceed 100% of the potential lost revenue
You must check the date from which these rules apply for the tax or duty you are dealing with. See CH81011 for full details.
It is possible for a penalty to be imposed on both a person (P) and another person (T) in respect of the same inaccuracy, see CH81075.
In this situation the aggregate amount of the penalties must normally not exceed 100% of the potential lost revenue. The only exception to this rule is in some instances where the inaccuracy involves an offshore matter and the tax at stake is income tax or capital gains tax, see CH116800.
FA07/SCH24/PARA12 (4 & 5)