Key points
- Underdeclaration may lead to non-financial sanctions.
- Penalty mitigation on publication of defaulter details.
- Could HMRC resist full mitigation to allow publication?
- The managing serious defaulters regime can result in increased HMRC oversight and costs.
As the initial furore over Covid-19 dies down and the coronavirus job retention scheme (CJRS) is phased out HMRC is starting to ramp up its enquiries. The quickest way for the department to gather money back into the state’s coffers is to focus on tax evasion – in other words those who have deliberately underdeclared their income – and specifically undeclared income and gains from overseas assets.
The reasons are two-fold. First the penalties for deliberate behaviour are higher than for those who took reasonable care or were simply careless. Further the penalties for tax offences relating to overseas assets are even higher and can result in a jail sentence...