ECH21137 - Penalties: Raising Formal Penalty Determinations - Initial Penalties arising under S98(1)(a) or S98(1)(b) TMA 1970


ECH21136 explains the initial action to be taken on all cases when raising formal penalty determinations.

The initial penalty under S98(1)(a) or S98(1)(b) TMA 1970 will be determined by Commissioners. Information will be laid before the Commissioners by an officer of HMRC (Higher Officer or above).

The caseworker will

If the local Grade 6 and senior manager agree to pursuing formal penalties the caseworker will

  • prepare a brief (to be used by the officer laying the information) and
  • complete a set of 82 forms (see Note).

Note: When completing the set of 82 forms the caseworker must print the following number of copies

  • 82A – 2 copies – one copy for the Commissioners and one copy to be retained on file.
  • 82B – 3 copies – one copy to be retained by Commissioners, one copy for HMRC and one copy to be issued to the employer/contractor/subcontractor by the Commissioners.
  • 82C – 3 copies – one copy to be retained by Commissioners, one copy to be issued to the employer/contractor/subcontractor by the Commissioners and one copy for HMRC.

The senior manager will

If the Commissioners award the penalty they will determine the amount and issue form 82C. The caseworker will

The SAFE officer will

  • create a charge on SAFE and
  • return the documents to the caseworker along with a payslip.

The caseworker will then

  • issue the letters, payslip and an appeals note to the employer/contractor and
  • BF the case for 14 days

If the employer/contractor does not remedy the failure the contractor should

  • consider making a referral to the Local Grade 6 officer to determine daily penalties ( ECH21138).

If the employer/contractor appeals against any penalty determinations the caseworker should follow the guidance at ECH21260.

Assistance on completing the relevant documents and stencils is at ECH21136.