FA 2009, s 94 provides HMRC with power to publish information about any person if both of the following conditions are met:
- Ìý
•ÌýÌýÌýÌý in consequence of an investigation conducted by HMRC, one or more relevant tax penalties is found to have been incurred by the person
- Ìý
•ÌýÌýÌýÌý the potential lost revenue in relation to the penalty, or the aggregate of the potential lost revenue in relation to each of the penalties, exceeds £25,000
The following are relevant tax penalties for the purposes of FA 2009, s 94:
- Ìý
•ÌýÌýÌýÌý a penalty under FA 2007, Sch 24, para 1 (inaccuracy in taxpayer's document) in respect of a deliberate inaccuracy on the part of the person
- Ìý
•ÌýÌýÌýÌý a penalty under FA
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