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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 have an interest-bearing overseas bank account on which they do not declare the interest in their return.

• Assets situated or held in a territory outside the UK. ‘Assetsâ€� 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 - for these purposes currency includes sterling.

For example, the person may own or dispose of land or buildings overseas. »Ê¹ÚÌåÓýappy may not include the correct amount of income from property or gains from disposals on their return.

“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 have a trade (or a branch of a trade) overseas but omit the profits from their return.

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

FA07/SCH24/PARA4A

TCGA92/S21(1)