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Taxpayer behaviour is a major influence on HMRC penalty calculations
KEY POINTS
- The CIOT’s initial review of the penalty regime suggested a “soggy middle ground” where HMRC might be reluctant to find deliberate behaviour.
- A tightening up of the “deliberate” definition now means that HMRC may apply the benefit of hindsight.
- HMRC may be seeking cases to take to the tribunal.
- Deliberate behaviour can mean higher penalties with no possibility of their suspension.
- Naming and shaming and inclusion in the managing serious defaulter programme can be real risks where deliberate behaviour is proven.
- The possibility of a tax investigation covering 20 years should not be overlooked.
The creation of HMRC in 2005 resulted in a significant harmonisation of the powers of the former Inland Revenue and HM Customs & Excise departments.
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