A company is a repayment trader and was receiving quarterly repayments of c £5k per quarter. It was party to a large sales transaction in qtr ended Dec 12 and was due to make a payment to HMRC of c£200k. It didn't do this and indeed has not filed any returns since then and 16 returns are due to HMRC. (There are some genuine reasons for this failure which I won't go into here , but the company accepts this is their doing and is prepared to accept the consequences and now wishes to come clean)
The net position is that during the past 4 years their vat ledger now shows that they are in credit with HMRC of c40k.
Quite apart from the one qtr ended Dec 12, every return (albeit not submitted) has shown a repayment due from HMRC.
For some reason HMRC have never corresponded with this company to request a return nor have they removed them as a registered business.
What is the overall penalty situation ?