Non-resident client started to receive UK State pension in 2013/14. Accountant advised that this was not taxable in the UK and so omitted from tax returns for 2013/14 to 2016/17. In my view client took reasonable care as they told the accountant about the income; and for the client to know otherwise would have probably required them to interpret the DTA.
Voluntary disclosure now being made. As "reasonable care" selected, the HMRC Disclosure system only gives the opportunity to disclose back to 2016/17.
a) Do you agree that reasonable care is the correct choice (therefore 0% penalty)?
b) What action if any would you take regarding the years that have dropped out? Advise HMRC which would then lead to an invitation to make voluntary restitution without penalties? Or stay silent?