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HMRC internal manual

Senior Accounting Officer Guidance

What to do when there may have been a failure or inaccuracy: Penalties Consistency Panel directs the Customer Compliance Manager when there may have been a main duty failure or inaccurate certificate

The Penalties Consistency Panel (the panel) will review the circumstances of the case and will either

  • give the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker the authority to notify the Senior Accounting Officer (SAO) that there is a potential penalty situation and conduct further investigations to determine whether a penalty is actually due, or
  • inform the CCM, CET or Caseworker why no action is appropriate.

If the first bullet is the case, the panel will also ask the CCM, CET or Caseworker

  • to refer the matter back to the panel once all the information has been gathered, and,
  • with that second referral, to make a recommendation on whether a penalty should be charged or not.