CH72120 | Penalties for Failure to Notify: Types of failure to notify: Deliberate and concealed
From HM Revenue & Customs · Compliance Handbook
A failure to notify, see CH71220, is deliberate and concealed if the person
knows that they are required to notify us about the relevant obligation, see CH71300,
is able to do so, but
does not do so and takes active steps to conceal the fact that they are required to do so.
Concealing the fact that they should have notified us about a relevant obligation is the most serious level of evasion.
The act of concealment may include
creating false evidence of a non-taxable source to explain undisclosed taxable income
creating false stock records
creating false invoices to support inaccurate figures of turnover
backdating or postdating contracts or invoices
destroying books and records so that they should not be available
creating sales records that deliberately understate the value of the goods sold, the balance of the full price being paid separately to the person
concealing excise goods on which the duty has not been paid or deferred with ‘innocent’ goods.
Although the penalties for deliberate inaccuracies are civil monetary penalties, we also have a criminal investigation policy and will refer the most serious cases for consideration of criminal proceedings where appropriate.
For practical examples of deliberate failure to notify with concealment see CH72140.