IHTM08121 details the circumstances when you do
not need to refer to Compliance Group. If the case
is not covered by that guidance and the relevant de minimis limit (
IHTM09083) is exceeded you should refer
the case to Compliance Group for consideration of penalties with a
note explaining the position.
If the relevant limit is NOT exceeded you should make a clear
note on File 4 to indicate that the potential penalty has been
considered.
