CISR85170 - CIS fraud measures: S72B Officers’ Liability: Amounts
The full amount of the penalty should be attributed to the responsible company officer or officers. This will enable HMRC to recover the penalty from either the company or the officer(s) or a combination of the two, up to the full amount.
Where the penalty is attributed to more than one officer, it should usually be divided evenly unless the circumstances indicate that a different apportionment would be more reasonable. It is not usually possible to quantify relative blame between different roles. But if different officers have been responsible for different transactions, this should be taken into account where possible. HMRC cannot recover more than 100% of the penalty through issuing decision notices in relation to two or more persons.