Perhaps the most fundamental point to note about this particular consultation is that despite the fact it is positioned as part of the ‘tackling offshore evasion’ programme, HMRC are explicit that “we are looking for the RTC to address all noncompliance irrespective of the underlying behaviour or motivation”.
Any model of sanctions created alongside the requirement to correct must therefore recognise that the behaviours encountered in applying the regulation will not necessarily have involved any intention to understate or fail to account for tax.
