VCP11531 | Breach of Walking Possession Order: Discretion, reasonable excuse and mitigation: Discretion
From HM Revenue & Customs · VAT Civil Penalties
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.