Mr. Niall Cody:

There is a whole methodology of coming within the scale of publication. There has to be tax liability and there has to be interest. In certain cases, what happens in research and development credits is that there is no interest because this is a claim that has not been repaid. That would arise in certain VAT cases where people have claimed VAT incorrectly and we do not give it to them. There is the issue around penalties. Penalties only happen where there is gross carelessness or deliberate default. There is a grid in the chapter on medical consultants' tax affairs that sets out when the default happens and when it attracts a penalty above 15%. Many of our recoveries do not involve gross carelessness or deliberate default and are not published. For considerable sums of money and for small sums of money to be published, one has to meet certain rigorous conditions. I think I said it at the committee. It is really hard to be published. I am constantly surprised at how cases manage to get published and when those involved do not avail of the opportunities for disclosure.