In all cases where a penalty is considered appropriate,
even a nil penalty, you should set out in full
your reasons for arriving at the suggested abatement under each
heading (having followed the guidance at
IHTM36181 to IHTM36210. There is a form
(
IHTM36211) you can use for this if you
wish. Your proposed penalty calculation (either on the form or in a
memo) together with a summary of the background to the penalty
must then be referred to your SO manager. If the
SO manager has any doubt or difficulty over the proposed penalty
the advice of the Penalty Portfolio Holder should be sought.
If you are an SO investigator working your own case you
should refer your proposed penalty calculation (including nil
penalty calculations to the Penalty Portfolio Holder.
