This week's opinion

If a client makes a full unprompted disclosure of an error caused by a failure to take reasonable care and gives maximum assistance to HMRC in quantifying the tax due what is the penalty? Most readers would answer zero. It has always been the case that we can advise clients who have made errors that if they come clean and co-operate with HMRC to bring matters up to date they will not be penalised. Allowing taxpayers to put things right without fear of penalty is in everybody’s interest including HMRC’s. But can that same advice be given now? Just before Christmas HMRC issued a revised version of its factsheet dealing with inaccuracies (CC/FS7a). It has these extra words: ‘When calculating penalties for inaccuracies we’ll take into account how long it’s taken for you to tell us about the inaccuracy. If you’ve take a significant period (normally three years) to...