In November HMRC published a new list of taxpayers who are considered to have ‘deliberately defaulted’ on their liabilities. This is of course an exception to HMRC’s normal process of dealing with taxpayers’ affairs (including almost all investigations) on a confidential basis.
The published list would suggest that small owner-managed businesses are at greatest risk of being ‘named and shamed’ in this way. However the deminimis sum applied by HMRC (tax of only £25,000) means that potentially larger concerns could easily exceed this limit, e.g. if HMRC reviews and investigations were not handled on an effective and professional basis.
Please note that a legitimate dispute on technical or factual matters (even if this becomes protracted) should not be seen by HMRC as evidence of either non-cooperation or of ‘deliberate’ default.