HM Revenue & Customs have today announced that the deadline for notifications under the New Disclosure Opportunity is to be extended from 30 November 2009 to 4 January 2010.  Press release here and link here. 

Given the minimal take-up of the NDO to date, the last minute announcement, the very limited extension period, and the futility of expecting anything  of note to happen over the festive season, what is the real reason for the extension ?  

Is it in order that Dave Hartnett has the opportunity to treat us with his new upcoming  YouTube video ?  Sad Git in a Bad Suit II: The Sequel.  Unfortunately, probably not.

But if one supposes that HMRC surely cannot be as inept as they appear, might this seemingly pointless extension now reflect HMRC working on some manner of dubious bluff strategy. After all,  someone, somewhere within the Revenue must think they have a handle on what the Revenue are doing. 

Is it that, deep down, HMRC do not want recalcitrant taxpayers to come forward for the NDO but, rather, HMRC want to wait until the NDO has expired, and then seek to launch an aggressive investigation initiative in which they expect to demand much higher penalty weightings using a notice argument to lessen attempts at mitigation.  If so, it could be interesting times for advisers in the next few years if the Revenue think they can fix taxpayers with notice on the back only of some haphazard mailshotting and Dave's dodgy vid.