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HMRC internal manual

Compliance Operational Guidance

Supporting Guidance: employer compliance: guidance by subject: penalties: abatement for disclosure

Disclosure means a disclosure of inaccuracy.

It implies

  • a positive
  • voluntary and
  • useful contribution

to your knowledge of the inaccuracies.

Circumstances will range from the extremes of

  • a complete and voluntary disclosure. Made spontaneously by an employer who has not been challenged and has no reason to fear early discovery. In this case an extra 10% abatement should be given, making 30% in all.

Note: In cases of voluntary disclosure the extra abatement is 10% not up to 10%. There should therefore be no cases with a 25% disclosure abatement.

  • No admission of inaccuracy (even after the First-tier Tribunal has determined appeals in our favour). In this case no abatement can be given.

See also COG914105 - Things to consider under disclosure.