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HMRC internal manual

Excise Civil Penalties Manual

How to apply the penalties: Double Jeopardy

You must ensure that taxpayers are not made liable for more than one sanction for the same conduct.

You must not issue a civil evasion penalty, see ECP1300, or take criminal proceedings for conduct which has been previously penalised by the issue of fixed, geared or daily penalties.

All such cases should be passed to Tax Administration, Litigation and Advice (TALA) for consideration, see ECP1700.

It may be appropriate to withdraw the lesser penalties depending on the circumstances of the particular case. This applies equally to financial and non-financial sanctions.