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HMRC internal manual

Compliance Handbook

Offshore matters: asset-based penalties: identification and valuation of assets: capital gains tax

Where the principle tax at stake, see CH122310, is capital gains tax (CGT) the following values will be used to calculate the asset-based penalty.

The asset is the asset that is the subject of the disposal (or deemed disposal) on or by reference to which the capital gains tax to which the standard offshore penalty relates is charged.

These values will be used for the purpose of calculating the asset-based penalty. The value of the asset will depend on whether the disposal (or deemed disposal) was of the full asset or a part disposal.

If the disposal or deemed disposal was of the whole asset, then the value of the asset is taken to be the consideration for the disposal of the asset that would be used in the computation of the gain under TCGA 1992. For guidance on calculating the value under TCGA 1992, see CG16200.

If the disposal is a part disposal of an asset, the value will be the full market value of the asset immediately before the part disposal took place. For guidance on establishing the market value, see CG16200.

FA 2016/Sch 22/Para 14