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HMRC internal manual

Compliance Handbook

Publishing details of deliberate tax defaulters: publication: time limits: first publishing a person's details - issues unlikely to lead to relevant penalties still to be resolved

CH191010+ and CH191020 provide guidance on when we can first publish a person’s details:

  • when there is one qualifying relevant penalty,
  • when there is more than one qualifying relevant penalty, and
  • when there is more than one qualifying relevant penalty but not all qualifying relevant penalties are final.

It may be that other issues from the compliance check, but which are unlikely to lead to relevant penalties, have still to be resolved. For example, there may be a difference of opinion on the tax treatment of some expenditure but even if that is resolved according to the HMRC view any inaccuracy would be despite taking reasonable care and not subject to a penalty.

The fact that such issues remain unresolved does not affect the publication time limits.

As soon as there is a penalty or penalties for which the answer to each of the five publication questions (CH190620) is “yes”, and those penalty/penalties are final, we will consider publishing a person’s details.

FA09/S94 (9)