SCHEDULES

SCHEDULE 25Penalties for deliberately withholding information

PART 2Liability to a penalty

Special reduction

I19

1

If HMRC think it right because of special circumstances, they may reduce a penalty under this Schedule.

2

In sub-paragraph (1) “special circumstances” does not include—

a

ability to pay, or

b

the fact that a potential loss of revenue from a taxpayer is balanced by a potential over-payment by a taxpayer.

3

In sub-paragraph (1) the reference to reducing a penalty includes a reference to—

a

staying a penalty, and

b

agreeing a compromise in relation to proceedings for a penalty.