So includes for carelessness or lack of reasonable care when making returns, it seems. I can see how that relates to say a tradesman under reporting income due, but is it really appropriate to a complex off shore trust to which shares have been transferred - to a family member. HMRC must have concluded that this was - at least in relation to the sale of the shares in youguv - unlawful, otherwise why would they be pursuing tax if there was legitimate avoidance. Very confusing, but doubtless the government investigation will clear this up.
Blup