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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
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Where CDF offer is made 30 June 2014 onwards: penalties and settlement of cases: different penalty regimes

Schedule 24 FA 2007 introduced a new regime of inaccuracy penalties for Income Tax, Capital Gains Tax, Corporation Tax, PAYE, NICs and VAT. FA 2008 extended this to the other taxes and also introduced penalties for failure to notify and VAT and Excise wrongdoing (Schedule 40 and 41 FA 2008). A penalty for failure to file on time was introduced by Schedule 55 FA 2009. These penalties only apply to periods after their introduction, they do not apply retrospectively.

Full instructions can be found in CH80000.

You should refer to the guidance at CH202000 to see the appropriate factsheets.

For periods not covered by the penalties mentioned above you will need to apply the rules in operation for the particular tax at that time. You will find the relevant guidance in EM4500 for ‘old’ direct taxes penalties and in VATCEP for VAT civil evasion penalties.

As the rules for each regime are different, it follows that for a period covered by more than one penalty regime, there will be different considerations to take into account and different levels of penalty for what might be the same behaviour.