Kugan Panchalingam and Justin Cobb consider what the terms reasonable care and excuse mean in practice
Since the introduction of the Requirement to Correct (RTC) legislation and the ongoing development of worldwide automatic exchange of information systems, advisers have been receiving unprecedented levels of enquiries from individuals.
Often, it is a simple case of the taxpayer not having reported bank interest. The figures tend to be insignificant in the taxpayer’s overall context and cases are quickly disclosed and agreed. At times, however, the offshore structure and the history leading up to the non-compliance can be very complex.