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HMRC internal manual

Excise Civil Penalties Manual

How to apply the penalties: Multiple contraventions

There are a number of circumstances where an action (or failure to act) can render a taxpayer liable to more than one penalty.

In such circumstances you must exercise discretion when deciding how many penalties to impose, taking into account the circumstances of the case and the perceived compliance effect of your actions.

You must not however, mitigate the penalties. If you are unsure with regard to how many penalties you should impose, you should discuss it with your manager.

Remember, you must keep a record of your decision making process, see ECP5700.

When faced with a multiple contravention situation you must first consider the compliance effect in relation to the following criteria

  • Revenue history
  • seriousness and nature of the error
  • amount of revenue at risk
  • mitigating circumstances
  • amount of penalty as a deterrent effect on the taxpayer
  • taxpayers ability to pay
  • status of taxpayer.

For further guidance on the broader categories of multiple contraventions, see ECP5810.