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An offshore matter results in a potential loss of revenue that is charged on or by reference to one of the following

• Income arising from a source in a territory outside the UK. For example, the person may fail to notify chargeability to income tax in respect of interest arising on an overseas bank account.
• Assets situated or held in a territory outside the UK.

‘Assets� takes its meaning from TCGA92/S21(1) so it covers all forms of property. It includes

• physical assets such as land and buildings
• options, debts and incorporeal property generally, and
• currency. Note that for these purposes currency includes sterling.
  
  

For example, the person may own or dispose of land or buildings overseas. »Ê¹ÚÌåÓýappy may fail to notify chargeability to income tax in respect of the income from property or capital gains from disposals.

“Held� has broad meaning that encompasses legal ownership and beneficial ownership. For example, UK situated assets can be “held� by a company in a territory outside the UK.

Activities carried on wholly or mainly in a territory outside the UK.
For example, the person may fail to notify a taxable activity overseas.

Anything having effect as if it were income, assets or activities of a kind described above.

FA08/SCH41/PARA6A

TCGA92/S21(1)