»Ê¹ÚÌåÓýapp

Telling includes

• admitting the wrongdoing
• disclosing the wrongdoing in full
• explaining how and why the wrongdoing arose.

What is important are the timing, nature and extent of the telling of the disclosure.

Timing

»Ê¹ÚÌåÓýapp timing is relevant to the period between the wrongdoing and the disclosure. Where a person has taken a significant period to correct their non-compliance in relation to either an onshore or offshore matter, or they would previously have been able to make a disclosure through one of HMRC’s offshore disclosure facilities, they can no longer expect HMRC to give them the full reduction for the quality of disclosure. A ‘significant periodâ€� is normally considered to be over 3 years but may be less where the overall disclosure covers a longer period.

If you consider that this may apply to your case, see CH95110 for further guidance.

Nature

»Ê¹ÚÌåÓýapp nature covers why the wrongdoing occurred. »Ê¹ÚÌåÓýapp person needs to show a positive approach to telling what has happened not just reacting to questions.

Extent

»Ê¹ÚÌåÓýapp extent is whether everything is disclosed to us. If there is only a partial disclosure then a full reduction will not be due. »Ê¹ÚÌåÓýappre is an overlap here with ‘helpingâ€� - a disclosure that makes no reference to the scale of a wrongdoing is not a complete disclosure.

Overall, the telling to you about the disclosure must be positive and as complete as possible.