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HMRC internal manual

Compliance Handbook

Offshore matters: additional information: overview

A person discloses an inaccuracy or failure to HMRC by

  • telling HMRC about it
  • giving HMRC reasonable help in quantifying the inaccuracy or unpaid tax
  • allowing HMRC access to records.

Schedule 21 FA 2016 introduced a new element to the quality of a disclosure in relation to an offshore matter or offshore transfer, see CH100000. ‘Additional information’ is now to be taken into account alongside telling, helping and giving when considering the quality of any disclosure to HMRC. This additional information applies to disclosures in relation to a penalty raised under

  • Schedule 24 FA 2007 paragraph 1 - Inaccuracy in taxpayer’s document
  • Schedule 41 FA 2008 paragraph 1 - Failure to notify
  • Schedule 55 FA 2009 paragraph 6 - Penalty for failure to make a return more than 12 months after the filing date.

The standard and minimum penalties that are chargeable are set out in the relevant legislation for each of the above penalties. Penalties start at the standard rate and the level of any reduction to the penalty ultimately charged depends on the quality of disclose to HMRC.

Statutory Instrument 2017/345 defined what is considered to be additional information. This guidance will aim to outline that definition and provide practical examples.

Schedule 21 FA 2016

SI 2017/345