Gravity: what to take into account?
When you consider the abatement in respect of the gravity of the offence you need to look at the circumstances which resulted in tax being underpaid as a result of an incorrect account, information or document. You are not concerned with what happens during the course of the enquiry. You will need to take into account the reasons why the account, information or document was incorrect and the amount of tax underpaid (IHTM36202).
Broadly speaking, the less serious the matter and the lower the tax underpaid the higher the abatement.
Seriousness will range from a minor degree of negligence on the one hand to a case of serious fraud on the other.