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HMRC internal manual

VAT Small and Medium Enterprises Assurance Manual

Event audit screens on EF: Reasonable excuse and mitigation: Introduction

If the trader has a “reasonable excuse” they will not be liable to a penalty.Guidance on what constitutes reasonable excuse can be found in V1-27 Civil penalties,section 6. If you are satisfied that no reasonable excuse exists, you must use yourdiscretion and give mitigation if there are grounds to do so. You should consider theMitigation framework in V1-27 Civil Penalties, section 15.

Determining whether the trader has a reasonable excuse, or if mitigation can be applied,will be a subjective process. It will depend on the views you have formed about thetrader’s attitude to compliance and the possible impact of external factors.

Clearly it is much easier to make an informed decision at the time of the visit, as youwill be aware of the circumstances that gave rise to the errors. This is a more effectiveuse of time that waiting for the Penalty liability Notice to be issued, which could takeplace sometime after the visit.