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HMRC Penalties and Compliance Checks - Major Points

1 Inaccuracy in documents of a specific type given to HMRC

(a) Within the scope? (inaccuracy in doc, underassessment, failure to correct inaccuracy).

(b) Careless/deliberate.

(c) What is careless? Please click here for further details.

(d) Penalty is percentage of PLR.

(e) Impact of using an agent. Please click here for further details.

(f) HMRC's view, examples and relevance.

(g) Reduction for prompted and unprompted disclosure.

(h) Quality of disclosure.

(i) Special reduction.

(j) Suspension.

(k) Assessment, review and appeals.

(l) Onus and burden of proof.

(m) Evidence.

2 Senior Accounting Officer

(a) Materiality.

(b) Overseas companies.

(c) SME subsidiaries.

(d) Change of ownership.

(e) Indemnities and risk (ongoing and change of ownership).

3 Compliance checks

(a) Role of FTT re notices and inspections.

(b) LPP.

(c) Inspections and refusal/withdrawal of consent.

(d) Conduct during inspections.

(e) Admissibility of improperly obtained evidence.

4 FTT and statutory reviews. Please click here for further details.

5 SDLT – Notification by all users of DOTAS SRNs.

6 Agents and reasonable excuse. Please click here for further details.