My client has made a voluntary disclosure of untaxed income. It’s clear in the circumstances that at worst this is “failure to take reasonable care”.
HMRC have been provided with details of the income going back to 1999/00. HMRC have now issued a schedule calculating the tax due back to 1999/00 and have described it as a “request for payment”. No formal enquiry has been opened as far as I can see. The only reference to such matters from HMRC is “I am carrying out a check” and “if I have to make an assessment it will be under s29 TMA1970.”
As it turns out, the oldest year has the highest tax bill, and of course interest would be worst for that year also.
What response should be given to HMRC? Say “sorry mate, you can only go back 6 years for failure to take reasonable care”? Not sure how to bring matters to a conclusion that is cheapest for my client without HMRC throwing their toys out of the pram.