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The new penalties regime for offshore evasion

KEY POINTS

  • Consultation will take place on further proposals for a “strict liability” rule for offshore under-declarations.
  • After various measures in recent years FA 2015 introduced further penalties relating to offshore tax liabilities.
  • A new “category 0” will be added to those in FA 2007 sch 24.
  • New penalties will apply where assets are moved from a “specified territory” to a “non-specified territory”.
  • Withdrawal of the various disclosure facilities means urgent action should be taken to resolve overseas tax problems.

It is common knowledge that for some years HMRC have been striving to find undeclared tax linked to assets and structures held overseas.

Numerous initiatives have been implemented such as: the formation of the Offshore Co-ordination Unit (OCU); enhanced penalties of up to 200% of the...

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