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HMRC internal manual

Senior Accounting Officer Guidance

What to do when there may have been a failure or inaccuracy: discussing reasonable excuse when there may have been a main duty failure or an inaccurate certificate

When the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker tells the person about the potential penalty situation relating to a main duty failure or inaccurate certificate, see SAOG19400, the person may claim that they had a reasonable excuse for the failure.

CCMs, the CET or Caseworkers can find guidance on reasonable excuse at SAOG20000.

If such a claim is made the CCM, CET or Caseworker must consider it and include it in their second referral to the Penalties Consistency Panel, see SAOG19600.