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HMRC internal manual

Compliance Handbook

Offshore matters: asset-based penalties: definitions: offshore potential lost revenue

The offshore potential lost revenue (PLR), in relation to a tax year, is the total for the year of:

  • the PLR used to calculate the standard offshore tax penalty charged under Sch 24 FA 2007 or Sch 41 FA 2008, and
  • the liability to tax used to calculate the standard offshore penalty charged under Sch 55 FA 2009, or
  • the PLR used to calculate the failure to correct penalty charged under Sch 18 FA (No 2) 2017.

When calculating the PLR, different ordering rules apply when a standard offshore tax penalty and one or more other penalties are assessed. This is referred to as a combined penalty. For further guidance on combined penalties, see CH122170.

Only the potential lost revenue or liability to tax relating to the standard offshore tax penalty is taken into account in calculating the offshore PLR.