Part 2 Amount of Penalty

Part 2 Amount of Penalty

Amount of penalty

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(1)     The penalty payable under paragraph 1 is 200% of the offshore PLR attributable to the uncorrected offshore tax non-compliance (subject to any reduction under a provision of this Part of this Schedule).

(2)     In this Part of this Schedule “the uncorrected offshore tax non-compliance†means—

(a)     the relevant offshore tax non-compliance, in a case where none of it is corrected within the RTC period, or

(b)     so much of the relevant offshore tax non-compliance as has not been corrected within the RTC period, in a case where part of it is corrected within that period.

Offshore PLR

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(1)     In this Schedule “offshore PLRâ€, in relation to any offshore tax non-compliance means the potential loss of revenue attributable to that non-compliance, to be determined as follows.

(2)     The potential lost revenue attributable to any offshore tax non-compliance is (subject to sub-paragraphs (5) and (6))—

(a)     if the non-compliance is a failure to notify chargeability, the potential lost revenue under the applicable provisions of paragraph 7 of Schedule 41 to FA 2008 (or, where the original offshore tax non-compliance took place before 1 April 2010, the amount

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