A penalty is chargeable where

a person has encouraged, assisted or otherwise facilitated another person to carry out offshore tax evasion or non-compliance, and

the two conditions at CH124400 are satisfied (FA16/Sch20/Para1).

A person carries out offshore tax evasion or non-compliance if they

commit a relevant offence, or

engage in conduct that makes them liable to a relevant civil penalty relating to income tax, capital gains tax or inheritance tax.

Relevant offence

The relevant offences are

cheating the public revenue involving offshore activity

fraudulent evasion of income tax involving offshore activity (TMA70/S106A)

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