The following Owner-Managed Businesses guidance note by Tolley provides comprehensive and up to date tax information covering:
From 6 April 2011, increased penalties are levied where a penalty for failure to notify a liability involves an offshore matter or (from 1 April 2016) an offshore transfer. Under these rules the maximum penalty can be up to 200% of the tax at stake depending on a number of criteria. Full details are in Simon’s Taxes A4.575A (subscription sensitive).
The rules in relation penalties for failure to notify a liability which involve offshore matters or transfers only apply when all of the following criteria are met:
FA 2008, Sch 41, paras 6–6A; SI 2016/456 (subscription sensitive); CH114100
Therefore, these increased penalties can be levied on individuals (including those who are self-employed or in partnership), trustees and personal representatives who fail to notify their liability to tax, as these are the people who are liable to income tax, capital gains tax and inheritance tax.
An ‘offshore matter’ is one where the PLR arises from:
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