Client has failed to file tax returns since the year 05/04/2006 due to various issues in that year that led to him burying his head in the sand for the next 9 years.
We have completed and filed 2013, 2014 and 2015.
There have been determinations for 2009 and prior, and we're now too late to file a return to replace them.
My question is therefore in respect of the returns for 2010, 2011 and 2012. There are refunds due for 2011 and 2012 with a large capital loss to carry forward, and there's likely just a small liability for 2010.
I believe HMRC should still accept these given the guidance here: https://www.gov.uk/government/publications/income-tax-time-limits-for-se...
But what happens if not? Guidance states that Determinations and penalties would be considered, but he's already had maximum penalties for each year and we're now past the Determination time limit. From what I can see it could just be Discovery, and they may refuse to process the refunds?
Any advice appreciated, none of the material I've found deals with such late issues!