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HMRC internal manual

Compliance Handbook

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HM Revenue & Customs
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Publishing details of deliberate tax defaulters: glossary of PDDD terms

 

Deliberate failure or wrongdoing A failure penalised under Schedule 41 FA08 and for which deliberate or deliberate and concealed behaviour has been established.
   
Deliberate inaccuracy An inaccuracy in a tax return or other document penalised under Schedule 24 FA07 that is caused by deliberate or deliberate and concealed behaviour by the person.
Deliberate default The term we use in this guidance for an inaccuracy, failure, omission or wrongdoing that gives rise to a relevant penalty, see CH190500.
Deliberate defaulter A person who incurs a relevant penalty, see CH190500.
Deliberate tax default In this guidance we use the term deliberate default.
Deliberate tax defaulter In this guidance we use the term deliberate defaulter.
Disclosure A person makes a disclosure by
  • telling HMRC about it (telling), see CH82440,
  • giving HMRC reasonable help in quantifying the amount of the inaccuracy or under-assessment (helping), see CH82450, and
  • allowing HMRC access to records for the purpose of ensuring that the inaccuracy or under-assessment is fully corrected (giving access), see CH82460.    
      Investigation A systematic or formal inquiry to establish the truth, see CH190684.
      PDDD period A guidance term meaning the period that is covered by the rules for publishing details of deliberate defaulters, see CH190664.
      Person The entity whose details may be published, see CH190400.
      Potential lost revenue The normal rule for potential lost revenue is that it is
  • an additional amount of tax due or payable as a result of putting right an inaccuracy, including an inaccuracy attributable to another person, see CH81075 and CH81165, or
  • an amount of tax due or payable as a result of a failure or wrongdoing, or
  • an amount of tax HMRC has wrongly repaid, or
  • an amount of tax that would wrongly have been repayable by HMRC,
  • an additional amount of tax due or payable as a result of failing to tell HMRC about an under-assessment, see CH81170.    
      Publication questions A guidance term meaning the five questions that we have to answer when we are considering whether we can publish a person’s details. We can only publish a person’s details if the answer to all five publication questions is ‘yes’. The publications questions are at CH190620.
      Qualifying potential lost revenue A guidance term meaning the total potential lost revenue that relates to any qualifying relevant penalties, see CH190720+.
      Qualifying relevant penalty A guidance term meaning a relevant penalty for which the maximum reduction for quality of disclosure has not been given, see CH190700+.
      Quality of disclosure The more a person tells, helps and gives access to us, the more the penalty will be reduced for disclosure. We measure the quality of disclosure using the criteria of telling, helping and giving. See CH190704.
      Relevant penalty A penalty for certain offences for which deliberate or deliberate and concealed behaviour has been established. There is a list of relevant penalties at CH190644.
      Representations Reasons that a person gives to HMRC as to why we should not publish their details.