A new client hasn't been asked by HMRC to file a tax return since 2016/17. I don't know why because he'd paid SA tax on a new self employment and investment income until then.
During 2017/18, he began to let the property he'd lived in and this continued until he sold it in 2019/20. He wants to bring his tax affairs up to date and has asked me to file returns for him. I calculate that he owes about £8k income tax but with no taxable gain on the flat. He accepts that there'll be interest and penalties to pay, but of course wants to minimise the penalties.
It's some years since I dealt with my only let property campaign disclosure, so I'm not overly familiar with it. I could simply file all three returns and wait to hear from HMRC, or I could register for an LPC disclosure for all three years. Or I could file 2019/20 (still within 12 months) and register to disclose the two previous years separately.
Are the failure to notify penalties likely to be similar in any case? It was a careless oversight - I think we're talking unprompted, and not concealed but I suspect it will be hard to persuade HMRC it wasn't deliberate. I suspect the relatively small amounts at stake and the self assessed nature of LPC gives the best opportunity to mitigate the penalties but, on the other hand, it would be simpler (and lower cost in fee terms) just to file the returns.
Any thoughts/experiences appreciated.