The plans were first trailed at Budget 2025, with plans for the introduction of a new criminal offence of ‘recklessness’ in direct tax.

HMRC has now released an extensive 5,000-word consultation paper, setting out plans to introduce a new offence.

HMRC finally explained their definition of ‘recklessness’, stating: ‘We use “reckless” in the way that term is used across a range of existing criminal offences. We mean that the maker of the statement was aware of the risk of their statement’s falsity or lack of truth, and they unreasonably proceeded to make the statement notwithstanding this risk of which they were aware.’

The Oxford English Dictionary defines recklessness as ‘Behaviour that shows a lack of care, heedlessness, or a conscious and unjustified disregard for danger and the possible consequences of your actions.’

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