SolvedCH27100 | Information & Inspection Powers: Penalties: Other penalty issues: Double jeopardy
From HM Revenue & Customs · Compliance Handbook
This page applies for notices issued
on or after 1 April 2009 under FA08/Sch36, or
on or after 1 April 2011 under CEMA79/S118
and for inspections carried out under FA08/Sch36 on or after 1 April 2009.
We cannot charge an initial, daily or tax-related penalty for failing to comply with
an information notice or an excise information notice under CEMA79/S118BA, or
deliberately obstructing an inspection
if the person has been convicted of a criminal offence, see CH27200, in respect of the failure or obstruction.