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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Penalties for VAT and Excise Wrongdoing: Calculating the penalty: Reducing the penalty: Quality of disclosure

The more a person tells, helps or gives access to us, the more the penalty will be reduced for disclosure.

The term ‘reduction for disclosure’ replaces the terms ‘abatement’ and ‘mitigation’ used in the previous penalty regimes.

To calculate the reduction for disclosure you need to consider the three elements of disclosure

  • telling us about it, see CH95000
  • giving us reasonable help, see CH95050
  • allowing us access to records, see CH95100.

As a guide you may weight the elements of disclosure as follows.

Element of disclosure Percentage  
Telling 30%  
Helping 40%  
Giving access 30%  
Total 100%  

For guidance on how to determine the quality of disclosure, see CH94900.

For an example, see CH94950.