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HMRC internal manual

Compliance Handbook

Dishonest tax agents: penalty for dishonest conduct: disclosure: quality of disclosure

The amount of the penalty is assessed having regard to the quality of disclosure. The more a person tells, helps or gives access to us, the higher is the quality of their disclosure.

To determine the quality of disclosure you need to consider the extent to which the person

  • told us about it, see CH184300,
  • gave us reasonable help, see CH184400, and
  • allowed us access to records, see CH184420.

FA12/SCH38/PARA26 (3) - (7)