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HMRC internal manual

Tobacco: Anti-smuggling or the duty to avoid facilitating smuggling

Penalty notices: Determining the amount of the penalty


The following framework has been developed to provide a structure for calculating the amount of any penalty, ensuring that all of the factors above are taken into account, and any penalty is proportionate to the size and nature of the breach. Each of the first eight factors is assessed and allocated a points score. The total maximum score for all eight factors is 100. Factor nine acts effectively as the Commissioners’ discretion. Each factor should be assessed and scored as follows: