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HMRC internal manual

Compliance Handbook

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HM Revenue & Customs
Updated
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Publishing details of deliberate tax defaulters: publication: time limits: first publishing a person’s details - more than one qualifying relevant penalty and not all penalties final

If not all the qualifying relevant penalties from the investigation are final, we may be able to publish the person’s details in relation to the qualifying relevant penalty or penalties that have become final.

One penalty final and one or more not yet final
More than one penalty final and one or more not yet final

One penalty final and one or more not yet final

If only one of the qualifying relevant penalties from the investigation is final, we can look at that qualifying relevant penalty. If its PLR is more than £25,000, we can choose to publish the person’s details in relation to that penalty on its own.

We can first publish the person’s details in relation to that penalty in the period

  • beginning with the date on which the penalty became final, and
  • ending 12 months after the date on which it became final.

More than one penalty final and one or more not yet final

If some but not all of the qualifying relevant penalties from the investigation are final, we can look at the group of qualifying relevant penalties that have become final, as long as the qualifying PLR for that group of penalties is more than £25,000. We can choose to publish the person’s details in relation to that group of penalties on its own.

We can first publish the person’s details in relation to that group in the period

  • beginning with the date on which the latest of all the penalties in that group became final, and
  • ending 12 months after the date on which the latest of all the penalties in that group became final.

For example, there may be five qualifying relevant penalties. Four are agreed and one is under appeal. We might choose to publish the person’s details in relation to the four agreed penalties without waiting for the appeal against the fifth penalty to be settled.

For cases where there are other issues from the compliance check that have still to be resolved, but which are unlikely to lead to relevant penalties, see CH191025.

FA09/S94 (7) & (8)