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New disclosure opportunity for medics

12th Jan 2010
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Medical professionals are being encouraged under a new Tax Health Plan to tell HM Revenue & Customs (HMRC) if they have understated income. Those who contact HMRC by 31 March 2010 to make a voluntary disclosure will be able to put their tax affairs in order simply and on the best available terms.

After that date, using information it holds about how much is paid to them, HMRC will carry out targeted investigations aimed at medical professionals who have not come forward. Substantial penalties or even criminal prosecution could follow for those who have undeclared tax liabilities.

Launching the campaign, Mike Wells, HMRC's Director of Risk and Intelligence, said:

"Our aim is to make it as easy as possible for people to come forward, make a full disclosure and benefit from the certainty of a reduced 10 per cent penalty that HMRC is making available to those who qualify for this opportunity.

"From April we will be using the information at our disposal to investigate medical professionals who have not declared their full income. I therefore strongly urge any in this group who think they may have outstanding tax liabilities on their income to get in touch with HMRC and get their tax affairs in order simply and on the best available terms.

"This is the first step in enabling those with undisclosed income or gains to avoid a full tax investigation together with much higher penalties. The message is clear: contact us before we contact you."

The Health Plan will operate in two stages:

  • From 11 January to 31 March 2010, medical professionals can register their intention to make a voluntary disclosure with HMRC.
  • By 30 June, those who have registered must have made their disclosure as well as arrangements to pay all tax interest and penalties due.

Disclosure can be made by telephone or email - full details are provided at the new web area devoted to the scheme.

HMRC has indicated that this is the first in a series of initiatives aimed at professionals. It is very likely that in each case the tax authority will be in posesssion of relaible information about income paid to the target group which will enable them to intiate a process of targetted compliance at the closure of the period allowed for disclosure. The tax helath plan comes with specific support resources aimed at the health profession, and the representative bodies are assisting the tax authority in providing support. FAQ's to support the scheme have been provided, and there is a special telephone line : 0845 600 4508 for prescriptive advice, lines are open Mon – Friday 8.00 am to 8.00pm.

Further reading: Is it fair to make other professionals 'wait their turn' in order to take advantage of tax amnesties asks RSM Tenon. Click here to read more.


Replies (2)

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By Mark Lee
13th Jan 2010 22:03

Not a tax 'amnesty'

HMRC make the point that these terms are in line with those offered for any full and accurate unprompted voluntary disclosure of tax liabilities. So is there really any incentive to come forward during the 'disclosure window' that closes on 31 March 2010?

I think there is. In effect HMRC are giving medical professionals a last chance to make an unprompted disclosure. From April it will be too late as HMRC will be writing to those professionals it believes have undisclosed income from, for example, NHS Trusts, private hospitals and private medical insurers. It seems that HMRC have been collating details of payments made by such entities that it suspects the recipients have not fully disclosed. From April the penalty will rise from 10% to at least 30% and possibly upto 100%.

It's worth stressing that in all such cases there is no tax 'amnesty'. The 10% penalty will be by reference to the tax previously unpaid. This will also be payable together with interest on the late payment.

Mark Lee

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By taxtroubleshooter
18th Jan 2010 12:44

Dentists on the waiting list

The Hot Topics page of the THP site says that HMRC is now keen to discuss the inclusion of dentists in the scheme. Notification for THP currently requires a GMC registration, which is much more restricted in reach than the "health professionals" and "medical professionals" tags which have been used to date, although the page also says that the THP helpline can take details of any voluntary notifications/disclosures from others not strictly within the ambit of THP.

According to HMRC "it is sensible for any person who thinks  they have unpaid tax liabilities to come forward and make a full disclosure to HMRC as soon as possible". Given the relative light touch of the disclosure programs compared with a traditional COP 9 enquiry I would like to see more substance to HMRC undertakings to deal with non-THP disclosures on similar terms as I suspect that the promised roll-out of further ODF/NDO/THP-style programs for other professionals is likely to encourage some to sit tight and wait for their particular scheme to come around without such reassurance.

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