Phil Berwick considers practical implications of the FA 2007 Sch 24 provisions
The new penalty rules introduced in FA 2007 Sch 24 brought about a fundamental change in the way that penalties are charged by HMRC for inaccuracies in tax returns.
The new provisions introduced the concept of behaviour-based penalties — the intention being that persons committing minor misdemeanours suffer a lower penalty than those guilty of serious offences. Each category of behaviour has a statutory minimum and maximum penalty that will apply with mitigation between these parameters possible depending on the quality of the disclosure.
When a disclosure is 'unprompted' (ie made at a time when the person making it has no reason to believe that HMRC have discovered or are about to discover the inaccuracy) the minimum penalty that can apply will be lower than that for a 'prompted' disclosure (all other...
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Phil Berwick considers practical implications of the FA 2007 Sch 24 provisions
The new penalty rules introduced in FA 2007 Sch 24 brought about a fundamental change in the way that penalties are charged by HMRC for inaccuracies in tax returns.
The new provisions introduced the concept of behaviour-based penalties — the intention being that persons committing minor misdemeanours suffer a lower penalty than those guilty of serious offences. Each category of behaviour has a statutory minimum and maximum penalty that will apply with mitigation between these parameters possible depending on the quality of the disclosure.
When a disclosure is 'unprompted' (ie made at a time when the person making it has no reason to believe that HMRC have discovered or are about to discover the inaccuracy) the minimum penalty that can apply will be lower than that for a 'prompted' disclosure (all other...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
