HMRC has published the above factsheet which gives detailed information about the higher penalties that may be charged for Income Tax and Capital Gains Tax when an offshore matter is involved.

HMRC may charge a penalty of more than 100% for:

• an inaccuracy in a return or document
• a failure to notify chargeability to tax
• the deliberate withholding of information where a tax return is more than 12 months late

when these involve offshore matters in certain categories of ‘territory’. Otherwise, the maximum penalty is 100%.

An offshore matter is an inaccuracy, failure to notify or deliberate withholding of information that relates to:

• income arising from a source in a territory outside the UK, or
• assets situated or held in a territory outside the UK, or
• activities carried on wholly or mainly in a territory outside the UK

which results in a potential loss of revenue or a liability that should have been shown on a tax return. The penalty percentage range is determined by the place where the income or gains arose, known as the ‘territory’. The factsheet is available at http://www.hmrc.gov.uk/compliance/cc-fs17.pdf