Offshore tax evaders—offshore penalties and other civil sanctions
Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons
Offshore tax evaders—offshore penalties and other civil sanctions

The following Private Client practice note produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons provides comprehensive and up to date legal information covering:

  • Offshore tax evaders—offshore penalties and other civil sanctions
  • What is an offshore matter?
  • What is an offshore transfer?
  • Condition for income tax and CGT
  • Condition for IHT
  • Requirement to correct offshore non-compliance
  • What is the offshore penalties regime?
  • History of offshore penalties regime
  • What are the offshore penalty rates?
  • Penalty rates for inaccuracies
  • More...

This Practice Note considers:

  1. requirement to correct and failure to correct penalties

  2. penalties for offshore matters or offshore transfers

  3. offshore assets moves penalties

  4. asset-based penalties and

  5. offshore tax evasion—12-year discovery assessment time limit

This Practice Note considers issues that are specific to the civil penalties and sanctions affecting offshore tax non-compliance. For guidance on the general penalty regime, see the: Tax penalties, interest and time limits—overview, which links to more detailed content.

For guidance on measures affecting offshore tax evaders committing a criminal offence, persons enabling offshore tax evasion, or corporates and other relevant bodies facilitating UK and offshore tax evasion, see Practice Note: Offshore penalties, sanctions and criminal offences—outline.

A tougher penalties regime applies to an individual's tax liabilities where non-compliance involves an offshore matter or an offshore transfer. From 1 October 2018 the level of penalty in respect of offshore matters and offshore transfers depends upon whether or not failure to correct penalties apply. HMRC guidance on the regime can be found in Penalties for offshore non-compliance: Compliance checks series—CC/FS17 and CH112100.

See also Timeline of penalties, sanctions and criminal offences in relation to offshore tax matters.

What is an offshore matter?

An inaccuracy, failure or withholding of information involves an ‘offshore matter’ if it results in a potential loss of revenue that is charged on or by reference to:

  1. income arising from a source in a territory

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