There is a penalty, in relation to relevant offshore asset moves, for income tax, capital gains tax and inheritance tax where assets are moved from a ‘specified territory’ to a ‘non-specified territory’ and the main, or one of main purposes, of the movement is to prevent the discovery of a loss of revenue by HMRC.

The new penalty is an additional penalty which can only be levied once a penalty has already been levied for ‘deliberate failure’ under:

FA 2007, Sch. 24, para. 1 (penalty for error in taxpayer’s document) (see ¶575ff.);

FA 2008, Sch. 41, para. 1 (penalty for failure to notify) (see ¶700ff.);

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