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HMRC internal manual

Enquiry Manual

Penalties: Culpability - Defences: Failure to Make a Return

A taxpayer may claim that they did not make the return on time because

  • their affairs were too complicated to be able to complete the return in time
  • they were let down by their accountant, in whom they had implicit trust
  • of illness, absence or family problems
  • they were too busy running the business
  • the records were lost preventing calculation of the correct figures
  • they had completed the form as far as possible and that the rest of the information would follow as soon as they had time or could obtain the required particulars
  • the delays were shorter than those of HMRC
  • the missing information had already been supplied in some other context.

See EM5152 for further guidance on what may be deemed as ‘reasonable excuse’.