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HMRC internal manual

VAT Civil Penalties

Mitigation Framework: Why and when we should mitigate a penalty: Why we should mitigate

Mitigation follows on from reasonable excuse and should be allowed where the trader has behaved reasonably, but does not have a reasonable excuse for the non- compliance.

Mitigation is discretionary and allows the circumstances which contributed to the infringement to be considered. Mitigation also allows for recognition and acknowledgement of the degree of co-operation and behaviour once a penalty liability has been established, and should be used to strike the right balance of penalty and deterrent.

It is important to consider mitigation in every case.