IHTM36000 - Penalties: contents

Late accounts
Failure to deliver an account
Failure to deliver an instrument of variation where additional tax payable
Incorrect account, information or document
Recording penalties
Accounting procedures
Human Rights and penalties

Introduction

IHTM36001Summary
IHTM36002Introduction
IHTM36010Types of penalty

Late accounts

IHTM36021When to seek a penalty?
IHTM36022Accounts subject to a penalty
IHTM36023Penalties chargeable

Procedures for taking penalties on late accounts

IHTM36031Summary of procedures (chart)
IHTM36032Who is responsible for requesting a penalty?
IHTM36033Identifying late accounts
IHTM36034Initial action in Compliance Group and PC&S

Penalty request letter

IHTM36041General
IHTM36042Standard letter
IHTM36050No response to request for penalty
IHTM36051Taxpayer claims reasonable excuse
IHTM36052Formal penalty proceedings
IHTM36053Settling the penalty enquiry

Reasonable excuse

IHTM36061General
IHTM36062Account lost or delayed in the post
IHTM36063Loss of financial records or other papers
IHTM36064Serious illness, absence or family problems
IHTM36065Bereavement
IHTM36066Not aware an account had to be delivered
IHTM36067Account, or the affairs of a deceased person, are too difficult
IHTM36068Pressure of work
IHTM36069Reasonable excuse: failure by an agent
IHTM36070Lack of information
IHTM36071Domicile outside the United kingdom

Failure to deliver an account

IHTM36081When can you seek a penalty?
IHTM36082Penalties chargeable

Failure to deliver an instrument of variation where additional tax payable

IHTM36091When can you seek a penalty?
IHTM36092Penalties chargeable

Incorrect account, information or document

IHTM36101When is an account, information or document incorrect?
IHTM36102Types of penalty
IHTM36103S.247(1) penalty
IHTM36104S.247(3) penalty
IHTM36105S.247(4) penalty
IHTM36106S.248(1) penalty
IHTM36107S.248(2) penalty
IHTM36108Time limit for seeking penalties

Investigating incorrect accounts, information or documents

IHTM36121What to do when you have an incorrect account, information or document (chart)
IHTM36122When to consider penalties
IHTM36123Criteria for considering penalties
IHTM36140Who is responsible for taking up penalty enquiries
IHTM36141Establishing whether a penalty is appropriate (chart)
IHTM36142Initial action in Compliance Group
IHTM36143Consulting valuers
IHTM36144Risk assessing the potential penalty

Raising enquiries into incorrect accounts, information and documents

IHTM36151General approach
IHTM36152Initial questions
IHTM36153Undervaluations (general)
IHTM36154Undervaluations of land or buildings

Issuing leaflet IHT 13

IHTM36156When and why is an IHT 13 issued?
IHTM36157Draft introductory wording for opening an investigation into an undervaluation
IHTM36158Draft introductory wording for opening an investigation into an omission

Dealing with taxpayer's replies

IHTM36161General
IHTM36162Do not make assumptions
IHTM36163Inconsistency in taking up cases
IHTM36164Claims that excess monetary deposits prevent a penalty being sought
IHTM36165Noting up penalty time limits
IHTM36166Death of person incurring a penalty
IHTM36167Deciding the amount of penalty due

Calculating the penalty

IHTM36171Board's policy
IHTM36172Effect of criminal proceedings
IHTM36173How to calculate a penalty (chart)
IHTM36174General approach
IHTM36175De minimis limits for seeking a penalty
IHTM36176Culpable tax
IHTM36177Factors to take into account when abating a penalty
IHTM36178Penalties due on more than one asset

Disclosure

IHTM36181What does disclosure mean?
IHTM36182What to allow for disclosure?
IHTM36183Additional abatement

Co-operation

IHTM36191What factors to take into account?
IHTM36192Genuine disagreements and 'external' intervention
IHTM36193Lack of co-operation by an agent

Gravity

IHTM36201What to take into account?
IHTM36202Size of underpayment
IHTM36203Calculating the abatement
IHTM36204Minor offences
IHTM36205Middle range offences
IHTM36206More serious offences
IHTM36207Most serious offences
IHTM36208S.248 penalties
IHTM36210Normal penalty loadings impracticable
IHTM36211Penalty calculation form

Negotiating a penalty

IHTM36221Summary of procedures (chart)
IHTM36222When to seek to agree a penalty
IHTM36223Prior approval for expected offer
IHTM36224Informing the taxpayer
IHTM36225Establishing culpability
IHTM36226Establishing fraud

Taxpayer does not make the expected offer

IHTM36231General
IHTM36232Normal negotiating limits
IHTM36233Culpability disputed
IHTM36234Culpability disputed but taxpayers prepared to make an acceptable offer
IHTM36235Payment of less than the expected offer made
IHTM36236Refusal to co-operate
IHTM36237Insufficient means
IHTM36240Request for time to pay

Instalment offers

IHTM36251General
IHTM36252Considering formal instalment arrangements
IHTM36253Re-calculating the penalty
IHTM36254Payments exceeding 2 years
IHTM36255Method of payment
IHTM36256Early settlement

Settling the penalty

IHTM36261Summary of procedures (chart)
IHTM36262Acceptable offer made
IHTM36263Checking the completed offer
IHTM36264Correcting errors in the offer
IHTM36265Taxpayer forwards own letter of offer
IHTM36266Delay in accepting the offer
IHTM36267Letter of acceptance
IHTM36268Administrative procedures

Improving future compliance

IHTM36271General approach
IHTM36272Joint property
IHTM36273Completing enquiries before delivering an account
IHTM36274Personal representatives employing agents
IHTM36275Valuations of land
IHTM36276Provisional estimates of value
IHTM36277Funding problems of tax due on delivery of the IHT400
IHTM36280Repayment of penalty
IHTM36281Repayment of tax

Fraud

IHTM36291What is fraud?
IHTM36292Examples of fraud
IHTM36293Dealing with suspected fraud
IHTM36294Role of Special Compliance Office

Negligence

IHTM36301What is negligence?
IHTM36302Who must you show to be negligent?
IHTM36303Onus of proof

Innocent Error

IHTM36311Dealing with claims of innocent error
IHTM36312Not aware of omitted asset or gift
IHTM36313Did not know that asset or gift had to be declared
IHTM36314Misinformed by a third party
IHTM36315Agent's failure
IHTM36316Advice given by IHT
IHTM36317Information supplied to another part of HMRC
IHTM36320Miscalculation

Letters of offer

IHTM36331Importance of correctness
IHTM36332Drafting the letter (general)
IHTM36333Checklist
IHTM36334Using precise terms
IHTM36335Consideration
IHTM36336Duties included
IHTM36337Taxpayer's default
IHTM36338Interest and penalties
IHTM36339Amount of the offer
IHTM36340Date of payment
IHTM36341Excluded duties
IHTM36342Signature
IHTM36343Tax year
IHTM36344Interest clause
IHTM36345Instalment offers (general)
IHTM36346Instalment offers (examples)

Standard letters of offer

IHTM36351Specimen form of offer involving penalties only
IHTM36352Specimen form of offer involving tax, interest and penalties
IHTM36353Specimen form of offer involving penalties only, payable by instalments - England, Wales and Northern Ireland cases
IHTM36354Specimen form of offer involving tax, interest and penalties, payable by instalments - England, Wales and Northern Ireland cases
IHTM36355Specimen form of offer involving penalties only, payable by instalments - Scottish cases
IHTM36356Specimen form of offer involving tax, interest and penalties, payable by instalments - Scottish cases

Reports to Tax Administration Advice(TAA)

IHTM36361General
IHTM36362Form of report

Recording penalties

IHTM36371General
IHTM36372database for non-COMPASS penalties
IHTM36373Creating a penalty record on COMPASS
IHTM36374Opening a penalty record on COMPASS
IHTM36375Enquiry not required
IHTM36376closing a penalty record on COMPASS
IHTM36377Entering data on the penalties database

Accounting procedures

IHTM36391Bringing payment of penalty to account
IHTM36392Payment not received by due date
IHTM36393Defaulting taxpayer
IHTM36394Repaying a penalty

Human Rights and penalties

IHTM36401Introduction
IHTM36402Article 6 advice
IHTM36403What you should say in a letter
IHTM36404What you should say at a meeting
IHTM36405What to do if the taxpayers refuses to co-operate

Public Funding for penalty hearings

IHTM36411When is Public Funding available?
IHTM36412When you must issue the Public Funding Leaflet
IHTM36413Public Funding and s.245 penalties
IHTM36414Requests for Public Funding leaflets