6(1)Sub-paragraphs (2) and (3) apply where—
(a)a standard offshore tax penalty has been imposed on P, and
(b)the potential lost revenue threshold is met,
in relation to more than one tax year falling within the same investigation period.
(2)Only one asset-based penalty is payable by P in the investigation period in relation to any given asset.
(3)The asset-based penalty is to be charged by reference to the tax year in the investigation period with the highest offshore PLR.
(4)An “investigation period” is—
(a)the period starting with the day on which this Schedule comes into force and ending with the last day of the last tax year before P was notified of an asset-based penalty in respect of an asset, and
(b)subsequent periods beginning with the day after the previous period ended and ending with the last day of the last tax year before P is notified of a subsequent asset-based penalty in respect of the asset,
and different investigation periods may apply in relation to different assets.