CH122600 - Offshore matters: asset-based penalties: penalty reduction for prompted or unprompted disclosure
»Ê¹ÚÌåÓýapp maximum amount of reduction available for disclosure will depend upon whether the case involves prompted or unprompted disclosure.
A disclosure is unprompted if it is made at a time when the person making it has no reason to believe that we have discovered or are about to discover the inaccuracy or under-assessment, see CH82420.
Otherwise it is a prompted disclosure.
Prompted
A case involves prompted disclosures where any of the standard offshore tax penalties to which the asset-based penalty relates was reduced on the basis of a prompted disclosure.
»Ê¹ÚÌåÓýapp maximum amount by which the standard amount of the asset-based penalty may be reduced is 20% of the standard amount in a case involving prompted disclosures.
Unprompted
A case involves only unprompted disclosures where
- in a case where the asset-based penalty relates to only one standard offshore tax penalty, that standard offshore tax penalty was reduced on the basis of an unprompted disclosure, or
- in a case where the asset-based penalty relates to more than one standard offshore tax penalty, all of those standard offshore tax penalties were reduced on the basis of unprompted disclosures.
»Ê¹ÚÌåÓýapp maximum amount by which the standard amount of the asset-based penalty may be reduced is 50% of the standard amount in a case involving only unprompted disclosures.
Further
guidance on the reduction for a prompted or unprompted disclosure can be found
at CH122625.