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8(1)This paragraph applies for the purposes of paragraph 7.
(2)P discloses a matter by—
(a)telling HMRC about it,
(b)giving HMRC reasonable help in relation to the matter (for example by quantifying an inaccuracy in a document, an inaccuracy attributable to the supply of false information or withholding of information or an under-assessment), and
(c)allowing HMRC access to records for any reasonable purpose connected with resolving the matter (for example for the purpose of ensuring that an inaccuracy in a document, an inaccuracy attributable to the supply of false information or withholding of information or an under-assessment is fully corrected).
(3)P assists HMRC in relation to an investigation leading to Q being charged with a relevant offence or found liable to a relevant penalty by—
(a)assisting or encouraging Q to disclose all relevant facts to HMRC,
(b)allowing HMRC access to records, or
(c)any other conduct which HMRC considers assisted them in investigating or assessing Q’s liability to such a penalty.
(4)Disclosure or assistance by P—
(a)is “unprompted” if made at a time when P has no reason to believe that HMRC have discovered or are about to discover Q’s offshore tax evasion or non-compliance (including any inaccuracy in a document, supply of false information or withholding of information, or under-assessment), and
(b)otherwise is “prompted”.
(5)In relation to disclosure or assistance, “quality” includes timing, nature and extent.
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