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Notify HMRC Omitted Income Pre-Engagement Letter?

Could Difference of a Day/A Week Make a Difference to Penalties Etc - I Suppose So. What You Think?

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Existing client told me over the phone he wants to disclose omitted income covering around 8 tax years.

I was just busying myself drafting a fresh Engagement Letter for this extra work and also drafting supporting correspondence explaining to the client the ins and outs of failure to disclose and back tax, interest and penalies etc.

It is taking and age doing all this, and it suddenly struck me that if HMRC were to jump the gun and instead of a voluntary disclosure "prompt" the client to disclose, then the penalties charged could be a lot higher.

Client is also likely to sit on Engagement Letter for a week or two due to old age and infirmity.

I am now thinking of "Notifying" HMRC of my client's intention to make a disclosure without client's signed engagement (his written authority to me to divulge to HMRC).

Do any readers see any dangers in starting the Digital Disclosure Service (DDS) now before I have my client's written authority to proceed.

Could he sue if he were to change his mind (I think this highly unlikely, but you never know).