Re: I call bullshit
If they don't, then HMRC can have a crack at them for not self-reporting and can apply higher penalties.
The initial report is simply that they might have some profits caught by the new tax, which is pretty hard to deny if you fit the fact pattern Then they have to give an initial estimate of what the amount is, which HMRC can then dispute.
I'm pretty sure HMRC will have a list with at least a few names on it that they're expecting reports from. They may be short on resources, so probably can't fight their corner as well as perhaps they should be able to (I speak as a taxpayer here, not as a tax advisor ;-) ), but they're not entirely stupid.