The Association is pleased to have the opportunity to comment on this consultation.
The ATT comments, sent to HMRC on 8 September 2011, on the final stage of the Review of Powers’ reforms of penalties in the tax system.
This consultation covers all penalties that have not previously been considered by the Review of Powers. It includes penalties relating to all the taxes and duties administered by HMRC, along with a small number of non-tax penalties, but excludes certain specific penalties from scope (see para 1.10 of the consultation document). This consultation considers and seeks views on the design principles and design features of a new penalty framework.
Previous Review of Powers work has looked at penalties for inaccuracies in returns, failure to notify, late filing and payment. For the purposes of this document the remaining penalties are termed ‘regulatory’ penalties.
14 September 2011