Increased penalties can be levied where a failure to notify, failure to file a return or an inaccuracy within a return involves an ‘offshore matter’ or ‘offshore transfer’. The maximum penalty under these rules is 200% of the tax at stake, with the specific penalty charged depending on the territory in which the income or gains arise. The categorisation of the territory depends on the transparency of the jurisdiction and the extent to which is shares information with HMRC, whether automatically or otherwise. See the Penalties for offshore matters and offshore transfers guidance note.
However, the Government felt that these rules did not sufficiently penalise taxpayers who moved their underlying assets from one territory in order to stay one step ahead of the international tax transparency agenda.
Following a consultation in 2014, legislation was introduced with effect from 27 March 2015 to introduce an additional penalty, on top of the penalty charged for the offshore matter, where the underlying assets had been moved or the taxpayer with beneficial ownership of the asset had changed his
Exporting goods ― proof of exportIn addition to the requirements laid down in the Exporting goods ― overview guidance note, businesses intending to zero-rate exported goods must hold satisfactory evidence that the goods have been delivered to a destination outside of the UK. If satisfactory evidence
Payments to trust beneficiariesThis guidance note considers the trustees powers to make payments and whether the payment made is income or capital.This guidance note is designed to give outline and background for accountants and tax advisers who deal with clients establishing trusts. It is not
Furnished holiday letsThis guidance note sets out the qualifying conditions for a property let to be treated as a furnished holiday let (FHL) for tax purposes and the subsequent tax implications.Whether or not a property qualifies as an FHL can make an important difference to the taxation