All of those working in the tax compliance field will be aware of HMRC's penalty regime and tendency to impose penalties for late returns, late payment or errors in the information supplied to HMRC. Every individual and business is expected to keep records that allow them to provide complete and accurate information to HMRC.

There is, of course, increased focus on and potential liability for penalties for those with offshore interests which are not adequately disclosed as and when required. It is not the purpose of this article to review the jurisdiction of HMRC regarding the imposition of penalties, but rather to discuss the position of the adviser whose client has or may incur a penalty.