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.