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HMRC internal manual

Compliance Handbook

Penalties for VAT and Excise Wrongdoing: Calculating the penalty: Reducing the penalty: Determining the quality of disclosure: Example

When you asked Habika for further information she initially denied any knowledge of the invoices and refused to allow access to any of her business records. You persisted, and eventually she provided details about all the invoices. There was some delay in providing the relevant documents to enable you to establish the total amount she had charged as VAT.

The quality of the disclosure is decided as

Telling 15% (of the full 30% see CH95000)
Helping 25% (of the full 40% see CH95050)
Giving access 20% (of the full 30% see CH95100)
Total 60% (of the full 100%)

So the quality of disclosure is 60%.