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Contents

Official guidance
Compliance Handbook

CH81100 · Penalties for Inaccuracies: Types of inaccuracy

  • CH81110 · The four types of inaccuracy
  • CH81120 · What is reasonable care
  • CH81122 · What is reasonable care - inaccuracies relating to avoidance arrangements
  • CH81123 · What is reasonable care - disqualified advice relating to avoidance arrangements
  • CH81124 · What is reasonable care - avoidance arrangements
  • CH81125 · Reliance on another person
  • CH81130 · Inaccuracy despite taking reasonable care
  • CH81131 · Inaccuracy despite taking reasonable care no penalty due - Examples
  • CH81140 · Careless Inaccuracy
  • CH81141 · Correction of errors for indirect taxes
  • CH81142 · Correction of errors for indirect taxes - monetary limits
  • CH81143 · Correction of errors for indirect taxes reasonable steps to notify - examples
  • CH81145 · Examples of careless inaccuracy
  • CH81150 · Deliberate but not concealed inaccuracy
  • CH81151 · Examples of deliberate but not concealed inaccuracy
  • CH81160 · Deliberate and concealed inaccuracy
  • CH81161 · Examples of deliberate and concealed
  • CH81165 · Inaccuracy attributable to another person
  • CH81166 · Actions of another person
  • CH81167 · Actions of another person supplying or withholding information
  • CH81168 · Intentions of another person - Examples
  • CH81170 · Under- assessment by HMRC
  • CH81180 · Onus of proof
  • CH81190 · Level of proof
  • CH81195 · Quality of evidence: poor co-operation
  1. Penalties for Inaccuracies: Types of inaccuracy: contents
  2. Penalties for Inaccuracies: Types of inaccuracy: Deliberate and concealed inaccuracy

CH81160 | Penalties for Inaccuracies: Types of inaccuracy: Deliberate and concealed inaccuracy

From HM Revenue & Customs · Compliance Handbook

You must check the date from which these rules apply for the tax or duty you are dealing with. See CH81011 for full details.

A deliberate and concealed inaccuracy is the most serious level of evasion. It occurs where a document containing a deliberate inaccuracy is given to HMRC and active steps have been taken to hide the inaccuracy either before or after the document has been sent to us.

As well as deliberately recording an inaccuracy, the person has to take active steps to cover their tracks by making arrangements to conceal the inaccuracy.

The act of concealment may include

  • creating false invoices to support inaccurate figures in the return

  • backdating or postdating contracts or invoices

  • creating false minutes of meetings or minutes of fictitious meetings

  • destroying books and records so that they are not available

  • systematically diverting takings into undisclosed bank accounts and covering the traces

  • invoice routing, for example the purported sale or purchase of goods through a tax haven company (with no activity undertaken by that company even though contracts exist showing the contrary) leaving profits untaxed in that company

  • creating sales records that deliberately understate the value of the goods sold, the balance of the full price being paid separately to the person

  • describing expenditure in the business records in such a way as to make it appear to be business related when it is in fact private (possibly with the supplier agreeing to change the description on the relevant invoices)

  • altering genuine purchase invoices to inflate their value

  • compiling false business accounts to support the availability of agricultural or business relief from IHT

  • mis-declaring the strength of alcoholic products on paperwork and accompanying documentation.

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 and concealed inaccuracies, see CH81161.

FA07/SCH24/PARA3 (1)(c)

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