ECSL Penalties: Voluntary disclosure

Client has not submitted ECSL for 3 consecutive quarters. Leniency if disclose voluntarily?

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A client sells services to EU businesses. They have submitted VAT returns but have not submitted ECSL returns for Mar 2016, June 2016 and Sept 2016. They have asked for help regarding the Dec quarter which we have submitted. But in terms of non-submission of the previous three, would HMRC be lenient if they submit voluntarily to correct the mistake rather than being told to? And if they can expect a penalty, how much is it likely to be i.e. will it be one penalty or three that have been increased due to continued non-compliance?

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