The Regulations appoint 1st January 2017 as the day on which section 162(1) of and Schedule 20 to the Finance Act 2016 (c. 24) come into force. Schedule 20 provides for a penalty to be payable by a person who has enabled offshore tax evasion or non-compliance by another person. Paragraph 1(2)(b) of Schedule 20 provides that a person has enabled another person to carry out offshore tax evasion or non-compliance where the person has encouraged, assisted or otherwise facilitated conduct by the other person that constitutes offshore tax evasion on non-compliance, within the meaning given to those terms in paragraph 1(2)(a) of the Schedule.

A Tax Information and Impact Note has not been prepared for these Regulations as they give effect to previously announced policy and are appointed day regulations.