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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
, see all updates

Penalties for inaccuracies: calculating the penalty: penalty reductions for disclosure: maximum and minimum penalties for inaccuracy involving an offshore matter: interaction of penalties

The guidance in this page applies only where

  • the tax at stake is income tax, capital gains tax or inheritance tax, and
  • the inaccuracy involves an offshore matter, and
  • the person gave HMRC an inaccurate return or other document which relates to 2011-12 or a later year on or after 6 April 2011.

It does not apply to the Construction Industry Scheme (CIS).

It is possible for a penalty to be imposed on both a person (P) and another person (T) in respect of the same inaccuracy, see CH81075. In this situation, where the inaccuracy involves an offshore matter that falls into category 1, the aggregate amount of the penalties must not exceed 100% of the potential lost revenue, see CH84974.

However, where an inaccuracy involves an offshore matter and falls into either category 2 or category 3, the aggregate limit is more than 100% of the potential lost revenue.

  • For category 2, see CH82483, the maximum aggregate figure is raised to 150% of the potential lost revenue.
  • For category 3, see CH82483, the maximum aggregate figure is raised to 200% of the potential lost revenue.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

FA07/SCH24/PARA1

FA07/SCH24/PARA1A

FA07/SCH24/PARA12 (4) & (5)