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HMRC internal manual

Compliance Handbook

Offshore matters: inaccuracies penalties: interaction of penalties

It is possible for a penalty to be imposed on both a person (P) and another person (T) in respect of the same inaccuracy, see CH81075. In this situation, where the inaccuracy involves an offshore matter that falls into category 1, the aggregate amount of the penalties must not exceed 100% of the potential lost revenue, see CH84974.

However, where an inaccuracy involves an offshore matter and falls into either category 2 or category 3, the aggregate limit is more than 100% of the potential lost revenue

  • For category 2, see CH116600, the maximum aggregate figure is raised to 150% of the potential lost revenue.
  • For category 3, see CH116700, the maximum aggregate figure is raised to 200% of the potential lost revenue.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

FA07/SCH24/PARA1

FA07/SCH24/PARA1A

FA07/SCH24/PARA12 (4) and (5)