Finance Act 2016 (c. 24)

SCHEDULES

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

PART 1 Liability for penalty

Reduction of penalty for disclosure etc by P

9 (1) If they think it right because of special circumstances, HMRC may reduce a penalty under paragraph 1.

(2) In sub-paragraph 1 “special circumstances” does not include—

(a) ability to pay, or

(b) the fact that a potential loss of revenue from one taxpayer is balanced by a potential overpayment by another.

(3) In sub-paragraph (1) the reference to reducing a penalty includes a reference to—

(a) staying a penalty, or

(b) agreeing a compromise in relation to proceedings for a penalty.