Consultation outcome

Tackling offshore tax evasion: a requirement to correct

This consultation has concluded

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Detail of outcome

This response document outlines the final design for the Requirement to Correct that will require taxpayers with undeclared past UK tax liabilities in respect of offshore interests to correct that situation by 30 September 2018 or face tougher penalties.

We are also seeking comments on the draft legislation by 1 February 2017. The legislation will be part of Finance Bill 2017 and come into force following Royal Assent to the Finance Act 2017.

Original consultation

This consultation ran from to


A consultation requiring taxpayers to ensure any undeclared UK tax liabilities in respect of offshore interests are fully disclosed to HMRC.


Consultation description

This consultation is about introducing new legislation that will require taxpayers with outstanding tax liabilities relating to offshore interests, where they have yet to put their UK tax affairs in order, to come forward and correct those liabilities by September 2018.

The consequence of not meeting the requirement and carrying out the necessary correction within the defined window would see the taxpayer subjected to a new set of legal sanctions for ‘‘failing to correct’’.

This consultation invites views on the proposed principles and design aspects including a toughened offshore penalties framework and introducing an obligation for taxpayers to put past affairs in order before tougher penalties are introduced and Automatic Exchange of Information agreements come into full effect in 2018.

A Requirement to Correct past offshore tax non-compliance was first announced at Autumn Statement 2015 and confirmed at Budget 2016 and, subject to agreement, legislation is planned through the Finance Bill 2017.