Prompted or Unprompted
A disclosure is:-
- Unprompted if is made when the person making it has no reason to believe that HMRC have discovered, or are about to discover, the relevant act or failure;
- Otherwise it is prompted.
HMRC have indicated that a disclosure will be treated as a prompted disclosure if it is made by a person after:-
- They became aware that HMRC had obtained information concerning the obligation to notify;
- HMRC had contacted them regarding the particular tax or activity to which the obligation to notify relates; or
- During the course of a compliance check concerning one tax liability, it becomes apparent that they have failed to notify liability to another tax or duty.
A disclosure made after an HMRC national campaign to highlight a particular type of potential non-compliance can still be treated as an unprompted disclosure.
For professional representation in your HMRC tax investigation, call Kinsella Tax Investigations on 0800 471 4546