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HMRC internal manual

Inheritance Tax Manual

Disclosure: what does disclosure mean?

‘Disclosure’ means a disclosure of irregularities. In other words - an admissionthat an account is wrong. It does not matter whether or not the taxpayer is able toquantify the irregularities at the time the disclosure is made. A complete disclosure willin some cases need to include a description of how the irregularity came about.

Disclosure implies a positive, voluntary and useful contribution to your knowledge of theirregularities. You may, for example, find that a statement made at an early stage of youinvestigation constitutes disclosure but the same statement, if made at a late stage inyour investigation, is little more than a worthless confirmation of what you have alreadyestablished.

Disclosure does not, in this context, include the production of information and documentsin response to your enquiries. These should instead be regarded as elements in arriving atthe abatement for co-operation (IHTM36191).

Examples of the specific things you need to look for when considering disclosure can befound at IHTM36182.