Managing serious defaulters

Produced by Tolley in association with

Owner-Managed Businesses

Guidance

Introduction

The managing serious defaulters (MSD) programme is an enhanced monitoring programme for certain individuals and businesses who have been found to have deliberately evaded the tax system and who HMRC therefore consider are ‘high risk’. It looks closely at a defaulter’s tax affairs to ensure that they are complying with all their tax obligations and tackles ongoing risk through early compliance activity. HMRC’s aim is to deter people from defaulting in the future and to reassure honest taxpayers that serious defaulters will be penalised and their tax affairs closely supervised.

Individuals and businesses will be notified by HMRC of their inclusion in the programme, and a copy of the letter should be sent to the authorised agent.

The letter is accompanied by factsheet CC/FS14.

It should be noted that there is no monetary limit that must be breached before someone is included in the scheme. There is also no right of appeal against inclusion in the scheme. However, the defaulter will have exhausted all appeals processes and internal review processes before

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Guy Smith

Senior Manager, Independent Tax

Guy joined Independent Tax in November 2022, returning to his roots handling tax investigations, disclosures and all manner of other HMRC tax disputes, on behalf of the firm’s clients. His remit also includes mentoring junior colleagues and managing the firm’s social media content and marketing output.Guy’s previous roles have included 15 years at HMRC and a similar length of time at Markel Tax, where he managed the team of Senior Tax Consultants, alongside delivering live presentations and webinars to accountants.Guy has been a consultant editor and writer for Tolley Guidance since July 2012 and a member of the ICAS Technical Bulletin editorial board since May 2014.

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