HMRC internal manual

Compliance Handbook

CH111100 - Offshore matters: introduction: overview

This guidance deals with penalties that involve an offshore matter. The date from which these penalties will apply is determined by the type of penalty and tax regime involved.

An offshore matter is an inaccuracy, failure to notify, failure to file on time or deliberate withholding of information that relates to

  • income arising from a source in a territory outside the United Kingdom (UK)
  • assets situated or held in a territory outside the UK
  • activities carried on wholly or mainly in a territory outside the UK,

and the inaccuracy or failure relates to offshore income or gains.

For specific guidance on

  • Failure to file on time penalties, see CH112000.
  • Failure to notify penalties, see CH114000.
  • Inaccuracies penalties, see CH116000.

A further penalty may be incurred if a person moves an asset that is connected with an underlying penalty they are already liable to. For more information about asset move penalties, see CH119000.

For guidance on how these penalties interact with the Human Rights Act (HRA), see CH300000.