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Where a Customer Compliance Manager (CCM), the Mid-sized Business Customer Engagement Team (CET) or a Caseworker considers that there may be a potential main duty or inaccuracy penalty situation they must not discuss a potential penalty with the Senior Accounting Officer (SAO) or issue a penalty without going through the authorisation process.

It is important that a CCM, the CET or a Caseworker does not discuss these types of potential penalties with an SAO until the matter has been fully considered within HMRC according to the following steps.

»Ê¹ÚÌåÓýappy must first discuss their concerns, with

• Large Business - with the Deputy Director
• Mid-sized Business - with the Assistant Director who must consult with their Deputy Director (Operations).

»Ê¹ÚÌåÓýapp Deputy Director or Assistant Director will decide whether on the basis of current information, it appears that there has been a main duty failure or inaccurate certificate. If the Deputy Director/Assistant Director decide that this is the case, the CCM, CET or Caseworker must send a submission via the Deputy Director in Large Business or Assistant Director in Mid-sized Business to the Penalties Consistency Panel (‘the panelâ€�), in accordance with existing Penalty Authorisation Guidance. »Ê¹ÚÌåÓýapp panel will direct the CCM’s, CET's or Caseworker's next action, see SAOG19300.

A template for submissions to the panel is available to all HMRC staff via the LB Operational Guidance Portal.

If the Deputy Director/Assistant Director decide that no further action should be taken on the case, a record of the reasons for this should be made and retained in the customer record.