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HMRC internal manual

Compliance Operational Guidance

HM Revenue & Customs
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Supporting Guidance: business records checks: referral for authority to charge a penalty for poor record-keeping

Where the local manager agrees that a record keeping penalty should be issued (see COG941840), the following actions must be taken first:

  • Visiting Officer’s actions

    • completes BRC18 (referral to BRC Authorised Officer) template
    • BRC18 saved and finalised in Caseflow documentum
    • refers case to manager for review
  • Manager’s actions are aimed at reviewing, where appropriate, that proportionate and effective use has been made of Sch 36 powers to overcome delay and the quality of evidence gathered and recorded at visits to support the issue of a record keeping penalty. The manager must:

    • Critically review the evidence recorded in the VO’s notebook for the initial visit and the follow up check and any linked correspondence saved within Caseflow documentum.
    • Discuss the case with the visiting officer
    • Record their findings, reasons for supporting the referral and provide the required assurance on the BRC18 template.
    • Save an updated version of the BRC18 template to Caseflow documentum, having ensured that all relevant supporting documents can be viewed in Caseflow.
    • Email the updated BRC18 to the BRC Authorised Officer.