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The Perils of Not Disclosing

Richard Cory Professional Support Lawyer at Clifford Chance gives us his thoughts on what the penalties for non-compliance with the new disclosure rules might be
What are the legal penalties for non-compliance with the new regime for disclosure of tax avoidance schemes in the Finance Act 2004 (FA 2004) Part 7?1 A tax practitioner's first reaction would be to look at the provisions of FA 2004 s 315 which sets out the penalties for non-compliance. As there is no reference elsewhere in the disclosure rules (or in the Inland Revenue guidance materials) to any other legal sanction for non-compliance Parliament appears to have intended that a person who is in breach of the disclosure rules should be liable only to a civil penalty to be imposed by...
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