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HMRC internal manual

Senior Accounting Officer Guidance

What to do when there may have been a failure or inaccuracy: second referral to the Penalties Consistency panel when there may have been a main duty failure or an inaccurate certificate

Once the Customer Relationship Manager (CRM), Mid-sized Business Customer Engagement Team (CET) or Caseworker has gathered all the information relevant to a penalty decision, they must make a second referral to the Penalties Consistency Panel (‘the panel’).

In the second referral the CRM, CET or Caseworker must present all the relevant information, including a clear record of

  • any technical specialist advise sought and provided, and
  • discussions with the Senior Accounting Officer (SAO)

They must also make a recommendation on whether a penalty should be charged or not.

The panel will then decide whether to approve penalty action, though this decision must still be authorised by the Director for Large Business or the Assistant Director for Mid-sized Business, see SAOG19800.