Aileen Barry reviews the top five tax developments in 2011 affecting investigations
The five key developments of 2011 in the tax investigations arena are as follows.
The new regime making its initial impact during 2011 penalises the behaviour giving rise to the tax default and rewards the quality of the subsequent disclosure. There is no longer any mitigation for the 'completeness' of the disclosure. Rather the penalty loading applies according to whether the act giving rise to the tax loss was careless deliberate or deliberate and concealed. All penalties can be significantly reduced according to whether the disclosure is unprompted that is without fear of HMRC immediate discovery.
...
