Publishing deliberate defaulter details (PDDD)

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Publishing deliberate defaulter details (PDDD)
  • Introduction
  • Who can be included?
  • Partnerships
  • The five publication questions
  • Informing the person about PDDD
  • Referring a case

This guidance note provides an overview of the publishing deliberate defaulter details (PDDD) programme that has been introduced by HMRC. This programme is operated alongside the Managing serious defaulters guidance note.

More information can be found on the PDDD programme in CC/FS13 .


FA 2009, s 94; CH500100

HMRC has the ability under FA 2009, s 94 to publish details of deliberate defaulters for all taxes and duties under FA 2007, Sch 24 and FA 2008, Sch 41.

A deliberate defaulter is an individual who incurs a relevant penalty for an inaccuracy, failure to notify or a VAT and excise wrongdoing. More information on these penalties can be found in the Penalties - summary of penalties that can be applied and Overview of the three penalties introduced from 1 April 2010 guidance notes.

HMRC introduced the PDDD programme in an attempt to:

  • send a clear message to all taxpayers that evading tax is wrong
  • to try and deter taxpayers from evading tax
  • provide an incentive to taxpayers that have evaded tax to make a full disclosure to HMRC in order to avoid having their details published
  • demonstrate to taxpayers who pay the right amount of tax that HMRC are serious about tackling non-compliance which can put them at an economic disadvantage
Who can be included?

HMRC can only publish a taxpayer’s details if:

  • a person has incurred a relevant penalty (deliberate or deliberate and concealed) or group of relevant penalties for:
    • inaccuracy in a return or document under FA 2007, Sch 24 (see the Penalties for inaccuracies

More on Investigations: