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HMRC internal manual

Compliance Handbook

Offshore matters: failure to file on time penalties: definition of an offshore matter

Amount of penalties involving an offshore matter

Information involves an offshore matter if the liability to tax which would have been shown in the return includes a liability to tax charged on or by reference to one of the following

  • Income arising from a source in a territory outside the UK. For example, the person may have an interest-bearing overseas bank account.

 

  • Assets situated or held in a territory outside the UK. ‘Assets’ takes its meaning from TCGA92/S21(1) so it covers all forms of property. It includes
    • physical assets, such as land and buildings,
    • options, debts and incorporeal property generally, and
    • currency. Note that for these purposes currency includes sterling.
    • For example, the person may own or dispose of land or buildings overseas.
  • Activities carried on wholly or mainly in a territory outside the UK. For example, the person may have a trade (or a branch of a trade) overseas.

 

  • Anything having effect as if it were income, assets or activities of a kind described above.

FA09/SCH55/PARA6A

TCGA92/S21(1)