IHTM36181 - Disclosure: what does disclosure mean?
‘Disclosure� means a disclosure of irregularities. In other words - an admissionthat an account is wrong. It does not matter whether or not the taxpayer is able toquantify the irregularities at the time the disclosure is made. A complete disclosure willin some cases need to include a description of how the irregularity came about.
Disclosure implies a positive, voluntary and useful contribution to your knowledge of theirregularities. You may, for example, find that a statement made at an early stage of youinvestigation constitutes disclosure but the same statement, if made at a late stage inyour investigation, is little more than a worthless confirmation of what you have alreadyestablished.
Disclosure does not, in this context, include the production of information and documentsin response to your enquiries. »Ê¹ÚÌåÓýappse should instead be regarded as elements in arriving atthe abatement for co-operation (IHTM36191).
Examples of the specific things you need to look for when considering disclosure can befound at IHTM36182.