HMRC have been reviewing this concession and put forward a number of suggested amendments which have given rise to a good deal of public comment. This concession allows (or requires) HMRC to waive tax where they have failed to make proper and timely use of information provided to them and where the taxpayer could reasonably have believed that their affairs were in order.
To their credit, HMRC have taken on board all the criticisms made about these proposals and have decided to leave the concession in place. This is obviously to be welcomed. The ability (or requirement) for HMRC to act fairly in these circumstances is not something which needs to be changed - indeed one might say that it is something to be supported. After all, there can be no abuse here - this is just a concession enabling HMRC to use their discretion to act fairly.
This must surely be a Good Thing. I seem to remember somebody Important saying: The quality of mercy is not strain'd ….it blesseth him that gives and him that takes…etc.