Full Disclosure? HMRC's Expectations For Accurate Filings

HMRC publishes new guidance for taxpayers setting out its expectations as to how taxpayers should ensure their submissions are 'correct and complete'.

HMRC's recently published Guidelines for Compliance 13 (the 'Guidelines') set out its clear expectations for taxpayers when filing returns or submitting documents that are declared to be correct and complete to the best of the taxpayer's knowledge. This post explores HMRC's views on legal interpretation, uncertain filing positions and the steps taxpayers should take to meet their compliance obligations, as set out in the Guidelines.

Background to the Guidelines

The Guidelines, which apply to both businesses and individuals making submissions in relation to any tax, have been published hot on the heels of HMRC's recent commitment (in its Transformation Roadmap (July 2025)) to reduce "legal interpretation disputes", which it defines as "cases where there is no avoidance, but where the customer's interpretation of