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HMRC internal manual

Compliance Handbook

Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: calculating the penalty: how to calculate amount of penalty

If both conditions A and B are met a penalty is chargeable on a person who has enabled another person to carry out offshore tax evasion or non-compliance (FA16/Sch20/Para1).

To calculate the penalty to be charged you will need to establish

  • the potential lost revenue, see CH124630
  • if the disclosure was prompted or unprompted, see CH124640
  • the quality of disclosure, see CH124650
  • any special reduction, see CH124660.

The penalty in most cases will be determined using the original potential lost revenue calculated on a person who has carried out offshore tax evasion or non-compliance, see CH124630.