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HMRC internal manual

VAT Civil Penalties

Breach of Walking Possession Order: Discretion, reasonable excuse and mitigation: Discretion

The starting point must be that HMRC apply the law correctly.

If, having considered the circumstances of a particular case, you think that the correct application of the law is not the best course of action it may be appropriate to exercise the Commissioner’s discretionary powers.

Case-specific advice should be requested in this scenario.