Key points
- HMRC can assess previously underpaid income tax and CGT within different timescales depending on the circumstances and taxpayer’s conduct.
- The requirement to correct legislation introduced extended time limits for offshore tax non-compliance which can now be assessed up to 5 April 2021.
- HMRC also have a permanent extension to the time limits for offshore matters and transfers.
- In order for the inaccuracy of a submission to lead to a penalty it has to be careless or deliberate.
- The maximum rate for a failure to correct penalty is 200% of the offshore potential lost revenue.
The past few years have seen a raft of new measures to extend HMRC’s ability to recover previously undisclosed tax liabilities and to assess related penalties. Many of these provisions overlap and attempting to chart a course through the legislation presents a challenging task.
This article looks at where we are now specifically...