A penalty is payable by a person ('P') who has enabled another person ('Q') to carry out offshore tax evasion or non-compliance, where conditions A and B are met1. Q carries out offshore tax evasion or non-compliance by committing a relevant offence or engaging in conduct that makes him liable (if the applicable conditions are met) to a relevant civil penalty, where the tax at stake is income tax, capital gains tax or inheritance tax; and P has enabled Q to carry out offshore tax evasion or non-compliance if P has encouraged, assisted or otherwise facilitated conduct by Q
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