SCHEDULES

SCHEDULE 38Tax agents: dishonest conduct

PART 4Sanctions for dishonest conduct

27Special reduction

1

This paragraph applies if HMRC propose to assess an individual to a penalty under paragraph 26 of £5,000.

2

If they think it right because of special circumstances, HMRC may take one or more of the following steps—

a

reduce the penalty to an amount below £5,000 (which may be nil),

b

stay the penalty, or

c

agree a compromise in relation to proceedings for the penalty.

3

“Special circumstances” does not include—

a

ability to pay, or

b

the fact that a loss of tax revenue from a client is balanced by an over-payment by another person (whether or not a client).