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HMRC internal manual

Compliance Handbook

Publishing deliberate defaulter details (PDDD): introduction

Section 94 of Finance Act 2009 allows HMRC to publish details of deliberate defaulters for all taxes and duties under FA07/Sch24 and FA08/Sch41.

Where your case meets the criteria for publishing details of deliberate defaulters, you must refer the case to the Managing Serious Defaulters Programme (MSD). This guidance tells you what these criteria are, and how to make the referral.

A deliberate defaulter is a person who incurs a relevant penalty for an inaccuracy, a failure to notify or a VAT or excise wrongdoing, see CH190500.

Publication is designed to

  • send out a clear message that evading tax is wrong
  • deter people from evading tax
  • provide an incentive to those who have evaded tax to make a full disclosure in order to avoid having their details published
  • show people who do pay the right amount of tax that we are serious about non-compliance which can put them at an economic disadvantage.

This guidance will help you

  • identify the penalties that are subject to the PDDD legislation and need to be referred for publication
  • explain to those who are subject to compliance checks when and how PDDD applies, and
  • submit cases to MSD for publication.

Where appropriate, it links to the technical guidance on PDDD at CH190000 onwards, which provides more detail on the legislation.