14(1)Paragraph 15 provides for reductions in the penalty under paragraph 6(3) or (4) or 11(3) or (4) where P discloses information which has been withheld by a failure to make a return (“relevant information”).
(2)P discloses relevant information by—
(a)telling HMRC about it,
(b)giving HMRC reasonable help in quantifying any tax unpaid by reason of its having been withheld, and
(c)allowing HMRC access to records for the purpose of checking how much tax is so unpaid.
(3)Disclosure of relevant information—
(a)is “unprompted” if made at a time when P has no reason to believe that HMRC have discovered or are about to discover the relevant information, and
(b)otherwise, is “prompted”.
(4)In relation to disclosure “quality” includes timing, nature and extent.