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Late compliance with requirement to correct rules

06 November 2018 / Amit Puri
Issue: 4671 / Categories: Comment & Analysis

A whole new world


  • Failure to correct penalties apply to taxpayers who have failed to disclose historic offshore income.
  • The penalty may be reduced if the person exposes the party who enabled their offshore non-compliance.
  • The offshore asset moves penalty could result in a fine of 300% of the tax due.
  • The taxpayer can appeal against the penalty at the First-tier Tribunal.
  • Insufficient funds will not amount to reasonable excuse.

The deadline for registering with HMRC to make a tax disclosure under the requirement to correct (RTC) rules has passed. These required any person with historic offshore irregularities at 5 April 2017 or earlier to correct them by 30 September 2018 (F(No 2)A 2017 Sch 18 and s 67). In practice they needed to register their intention to disclose by that date. Under normal circumstances they would have 90 days to make their disclosure and pay any additional taxes interest...

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