Corporate report

Penalties for a failure to correct certain offshore tax non-compliance

The current list of people found liable to a penalty for failing to correct their offshore tax non-compliance during the required period.

Documents

Details

HMRC may publish information about a person if:

  • they had relevant offshore tax non-compliance at the end of 2016 to 2017 which they were aware of and failed to correct within the required period (6 April 2017 to 30 September 2018)
  • they have incurred one or more relevant penalties, and either:
    • the offshore potential lost revenue (PLR) in relation to the penalty, or the aggregate of the offshore potential lost revenue in relation to each of the penalties, exceeds £25,000, or
    • the person has incurred five or more relevant penalties regardless of the total PLR

The law that allows this is paragraph 30 (1) of schedule 18 to the Finance (No2) Act 2017.

We will publish enough information to identify:

  • the person
  • the penalties charged for their failure to correct
  • the amount of offshore tax lost on which those penalties are based

The information will only be published once the penalties are final. If there is more than one penalty involved, this will be on the latest day when any of the penalties becomes final.

A penalty becomes final on either:

  • the day after the end of the appeal period if the person doesn’t make an appeal
  • the date when the appeal is finally determined
  • the date when a contract settlement is made

The law requires that those details published about a person are removed no later than 12 months from the date we first publish them.

The information may not be published if the amount of the penalty is reduced to the minimum permitted amount (100% of the offshore PLR) to reflect the quality of the disclosure made by the person or is reduced to nil because of special circumstances.

The lists of persons charged a penalty for their failure to correct their offshore tax non-compliance during the required period will not be captured for The National Archives.

Published 18 November 2021
Last updated 27 March 2024 + show all updates
  1. Added new section: 'Details first published 27 March 2024'.

  2. Added list first published 21 September 2023.

  3. Removed name first published 18 November 2021.

  4. First published.