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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
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Penalties for Inaccuracies: Calculating the penalty: Potential Lost Revenue: Inaccuracies that should not be grouped

You must check the date from which these rules apply for the tax or duty you are dealing with. See CH81011 for full details.

You cannot group inaccuracies

  1. that arise from different behaviours
  2. that arise from different types of disclosure, that is, unprompted or prompted, see CH82420 
  3. if suspension conditions, see CH83250, cannot be set for each inaccuracy , and
  4. if suspension conditions for all the inaccuracies cannot be aligned, or
  5. if the inaccuracies concern offshore matters that fall into different categories and the tax at stake is income tax or capital gains tax, see CH82480+.

For example

In a set of accounts three inaccuracies were identified, all relating to UK sources. Two inaccuracies were careless whilst the third was deliberate and concealed.

The first two inaccuracies can be grouped together as they have the same underlying behaviour. The reduction for disclosure will reflect the overall contribution of telling, helping and giving access, see CH82410, in arriving at the careless understatements.

The third inaccuracy will be dealt with separately as it falls into a different category of behaviour. The reduction for disclosure will reflect the overall contribution of telling, helping and giving access, see CH82410, in arriving at the deliberate and concealed understatement.

The multiple inaccuracy rules, see CH82250, will need to be considered as there are now two inaccuracies, one careless, and the other deliberate and concealed.