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EM5202 - Penalties: formal assessments and determinations: when to issue
You should issue formal penalty assessments and determinations when
constructive discussions leading to an agreed position are unlikely and any tax assessments are likely to becontentious and appealed EM5207, or the taxpayer requests early closure of our enquiries and the tribunal gives a direction EM1990.
You will also need to issue penalty assessments or determinations if exceptionally they were not considered when the tax assessments were issued, especially if any of the following
circumstances apply:
the taxpayer is elderly or seriously ill and there is a danger that death would lead to the restriction on penalties, see EM5002, or penalty time limits are in danger of expiring, see EM5001
and CH83040, or there is a serious risk that the taxpayer may leave the country permanently or remove their assets abroad. Previous page Next page
