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HMRC internal manual

Compliance Handbook

Charging penalties: calculating penalties: offshore matters: examples of territory categories

Your enquiry into Anthony’s 2024-25 self-assessment tax return, filed on 31 January 2026, reveals that he has omitted profits from his UK-based business and put the money into interest-bearing accounts in Ruritania. The interest arising in Ruritania has been omitted from Anthony’s returns.

He has also done this in the previous three tax years. In each of those years he has filed his tax returns on 31 January following the end of the tax year.

You check the territory category lists to see into which category Ruritania fell on each 31 January filing date from 31 January 2023 (for 2021-22) to 31 January 2026 (for 2024-25). You find that until a Treasury Order was made on 3 June 2024, Ruritania was in category 3. On 3 June 2024 it was moved to category 1.

The maximum penalties chargeable on the potential lost revenue (PLR) that relates to the offshore matters (interest arising in Ruritania) will be

2021-22 filing date 31 January 2023 200%
2022-23 filing date 31 January 2024 200%
2023-24 filing date 31 January 2025 100% (Treasury Order made 3 June 2024)
2024-25 filing date 31 January 2026 100%


The maximum penalties chargeable on the PLR that relates to the omitted profits from the UK business will be 100% for each year as an offshore matter is not involved.


For examples of when

  • an inaccuracy falls into one category and more than one category, see CH116500
  • a failure to notify falls into more than one category, see CH114500
  • the information in a failure to file case falls into more than one category, see CH112500.