This concerns a disclosure under the Worldwide Disclosure Facility. My view was that there was sufficient culpability to go back more than 6 years. HMRC disagreed (!) and invited an offer on equitable grounds aka voluntary restitution. HMRC emphasise that there is no obligation on the taxpayer to do so.
If I advise my client to decline to make a voluntary restitution for the out of time years, can HMRC come back with discovery?