[CH81195] Penalties for inaccuracies: types of inaccuracy: quality of evidence: poor co-operation
You must check the date from which these rules apply for the tax or duty you are dealing with. See CH81011 for full details.
Article 6 ECHR gives a person the right not to co-operate with us when we are considering penalties, see CH300100.
A person may choose not to co-operate with us because they wish to invoke these rights or because they believe they can gain an advantage by non-co-operation. If they are seeking to gain advantage it is likely that they will have failed to co-operate from the start of the check and the overall quality of disclosure will have been poor or non-existent throughout the check.