SCHEDULES

SCHEDULE 20Penalties for enablers of offshore tax evasion or non-compliance

PART 2Application of Schedule 36 to FA 2008: information powers

General modifications

I119

In its application for the purpose mentioned in paragraph 18(1) Schedule 36 to FA 2008 has effect as if—

a

any provisions which can have no application for that purpose, or are specifically excluded by paragraph 20, were omitted,

b

references to “the taxpayer” were references to the relevant person whose position as regards liability for a penalty under paragraph 1 is to be checked, and references to “a taxpayer” were references to a relevant person,

c

references to a person's “tax position” are to the relevant person's position as regards liability for a penalty under paragraph 1,

d

references to prejudice to the assessment or collection of tax included a reference to prejudice to the investigation of the relevant person's position as regards liability for a penalty under paragraph 1,

e

references to information relating to the conduct of a pending appeal relating to tax were references to information relating to the conduct of a pending appeal relating to an assessment of liability for a penalty under paragraph 1.