It is clear from the Saunders judgement that a tax payer may not be forced to produce evidence against himself that does not pre-exist independent of his will. The Allen decision does indicate that producing tax records is an acceptable requirement. However, it follows from that same decision that producing evidence on previous tax offences already committed under threat of severe penalty may still infringe upon a taxpayer’s right not to incriminate oneself. This exception included in the Allen decision deserve due attention.