In the event of an investigation HMRC will ask;
“In order to help me consider the behaviour involved and establish the penalty position, I would ask that you please state what systems were in place for the filing of your tax returns i.e. did you provide your tax advisers with information/documents and ask them to prepare your returns, did you ask them to prepare your return and then supply them with information/documents which they asked for, did your tax advisers send you a copy of the intended return for you to check before authorising its submission, did you meet with your tax advisers to discuss your tax return before/during its completion to check what was being returned.”
HMRC is clearly asking for a timeline and confirmation that the client had been proactive rather than inactive in supplying information to the agent.
By asking this, HMRC wants to find out how careful the client was in the preparation of the return, which will determine the amount of penalty charged. It is important that you supply full and accurate information to us as we can only work with the information you supply.