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HMRC internal manual

Compliance Handbook

Publishing details of deliberate tax defaulters: The publication questions: Question 3 - Was this relevant penalty found as a consequence of an investigation: Introduction

We can only publish a person’s details if we can answer ‘yes’ to all five publication questions at CH190620.

You only consider question 3 if you have answered ‘yes’ to question 1, see CH190640+, and question 2, see CH190660+.

Question 3 Was this relevant penalty found as a consequence of an investigation?


To answer this you need to consider


  • when a relevant penalty was found, see CH190684, and
  • whether there was an investigation, see CH190686, and
  • if there was an investigation, whether there was a single investigation or more than one, see CH190688, and
  • whether the penalty was found as a consequence of that investigation, see CH190692.

If you are considering more than one relevant penalty, you need to establish how many investigations have taken place and which relevant penalties relate to which investigation.

For PDDD purposes, we look at each investigation separately and apply the five questions in relation to each investigation. We cannot add together relevant penalties from different investigations.

If the answer to question 3 is ‘no’, we cannot publish the person’s details and therefore there is no need to consider questions 4 and 5.

If the answer to question 3 is ‘yes’, go on to consider question 4, see CH190700.

FA09/S94 (1)(a)