SAOG19500 | What to do when there may have been a failure or inaccuracy: discussing reasonable excuse when there may have been a main duty failure

When the Customer Compliance Manager (CCMor Mid-sized Business Caseworker tells the person about the potential penalty situation relating to a main duty failure, see SAOG19400, the person may claim that they had a reasonable excuse for the failure.

CCMs or Caseworkers can find guidance on reasonable excuse at SAOG20000.

If such a claim is made the CCM or Caseworker must consider it and include it in their second referral to the Penalties Consistency Panel, see SAOG19600.

At the same time, the customer may make representations that HMRC should exercise its discretion not to assess an SAO penalty, see SAOG18550.