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HMRC internal manual

Compliance Handbook

Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: publishing details of enablers

A person who is found liable to a penalty for enabling offshore tax evasion or non-compliance may have their details published by HMRC.

Conditions for publishing details

The Commissioners for HMRC may consider publishing details of a person if

  • a penalty for enabling offshore tax evasion or non-compliance has been assessed on the person, and
  • the potential lost revenue exceeds £25,000, or
  • a person has incurred five or more penalties for enabling offshore evasion or non-compliance in any five year period.

A person includes an individual or a company.

Before publication the Commissioners for HMRC must

  • inform the person they are considering doing so, and
  • afford the person the opportunity to make representations about whether these details should be published.


We cannot publish details of a person if the penalty is reduced by the maximum allowed for that disclosure or reduced to nil or stayed due to special circumstances.

Time Limits

There are certain time limits. These are:

  • No information may be published before the penalty becomes final. If there is more than one penalty the 12 months starts on the date on which all the penalties have become final.
  • No information may be published for the first time more than one year after the penalty becomes final.
  • We can only continue to publish these details for a maximum of 12 months from the date of first publication.

A penalty becomes final when the penalty has been assessed and

  • an appeal has not been made within the time limit, or if later
  • an appeal or final appeal is determined.


We may publish some or all of the following details:

  • The name of the person who incurs the penalty including any trading name, previous name or pseudonym.
  • The person’s address (or registered office, in the case of a company).
  • The nature of any business carried on by the person.
  • The amount of the qualifying relevant penalty or penalties.
  • The qualifying potential lost revenue (PLR) in relation to the qualifying relevant penalty, or the total of the qualifying PLR for all of the qualifying relevant penalties.
  • The periods when the inaccuracy, failure or wrongdoing that gave rise to the qualifying relevant penalty or penalties occurred.
  • Any other details that we consider necessary in order to make the person’s identity clear.

For further information on when HMRC can publish details, see CH190000.