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HMRC internal manual

Inheritance Tax Manual

Human Rights and penalties: Article 6 advice

Implicit in the fair trial provisions of Article 6 of the European Convention on Human Rights (EHCR) are rights which include a right to silence and a right not to self incriminate. We want to be sure we do not accidentally infringe those rights.

You must make it clear to taxpayers, and any agents acting for them, that they do not have any obligation to incriminate themselves. At the same time you should draw their attention to the potential to reduce any penalty which we might eventually seek, by making disclosures and co-operating with our enquiries.