[CH124300] Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: in what circumstances is a penalty payable
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.
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 penalty relating to income tax, capital gains tax or inheritance tax.
The relevant offences are
•cheating the public revenue involving offshore activity
•fraudulent evasion of income tax involving offshore activity (TMA70/S106A)