Reductions for disclosure
12(1)Paragraph 13 provides for reductions in penalties under paragraphs 1 to 4 where P discloses a relevant act or failure
(2)P discloses a relevant act or failure by—
(a)telling HMRC about it,
(b)giving HMRC reasonable help in quantifying the tax unpaid by reason of it, and
(c)allowing HMRC access to records for the purpose of checking how much tax is so unpaid.
(3)Disclosure of a relevant act or failure—
(a)is “unprompted” if made at a time when the person making it has no reason to believe that HMRC have discovered or are about to discover the relevant act or failure, and
(b)otherwise, is “prompted”.
(4)In relation to disclosure “quality” includes timing, nature and extent.