{
  "url": "https://openlegislation.uk/finance-act-2007/schedule-24/paragraph-4A",
  "json_url": "https://openlegislation.uk/finance-act-2007/schedule-24/paragraph-4A.json",
  "legislation": "ukpga/2007/11",
  "legislation_title": "Finance Act 2007",
  "legislation_url": "https://openlegislation.uk/finance-act-2007",
  "path": "schedule/24/paragraph/4A",
  "kind": "paragraph",
  "number": "4A",
  "heading": null,
  "text": "(1) An inaccuracy is in category 1 if—\n(a) it involves a domestic matter, or\n(b) it involves an offshore matter and—\n(i) the territory in question is a category 1 territory, or\n(ii) the tax at stake is a tax other than income tax or capital gains tax.\n(2) An inaccuracy is in category 2 if—\n(a) it involves an offshore matter or an offshore transfer ,\n(b) the territory in question is a category 2 territory, and\n(c) the tax at stake is income tax , capital gains tax or inheritance tax .\n(3) An inaccuracy is in category 3 if—\n(a) it involves an offshore matter or an offshore transfer ,\n(b) the territory in question is a category 3 territory, and\n(c) the tax at stake is income tax , capital gains tax or inheritance tax .\n(4) An inaccuracy “involves an offshore matter” if it results in a potential loss of revenue that is charged on or by reference to—\n(a) income arising from a source in a territory outside the UK,\n(b) assets situated or held in a territory outside the UK,\n(c) activities carried on wholly or mainly in a territory outside the UK, or\n(d) anything having effect as if it were income, assets or activities of a kind described above.\n(4A) Where the tax at stake is inheritance tax, assets are treated for the purposes of sub-paragraph (4) as situated or held in a territory outside the UK if they are so situated or held immediately after the transfer of value by reason of which inheritance tax becomes chargeable.\n(4B) An inaccuracy “involves an offshore transfer” if—\n(a) it does not involve an offshore matter,\n(b) it is deliberate (whether or not concealed) and results in a potential loss of revenue,\n(c) the tax at stake is income tax, capital gains tax or inheritance tax, and\n(d) the applicable condition in paragraph 4AA is satisfied.\n(5) An inaccuracy “involves a domestic matter” if it results in a potential loss of revenue and does not involve either an offshore matter or an offshore transfer .\n(6) If a single inaccuracy is in more than one category (each referred to as a “relevant category”)—\n(a) it is to be treated for the purposes of this Schedule as if it were separate inaccuracies, one in each relevant category according to the matters or transfers that it involves, and\n(b) the potential lost revenue is to be calculated separately in respect of each separate inaccuracy.\n(7) “Category 1 territory”, “category 2 territory” and “category 3 territory” are defined in paragraph 21A.\n(8) “Assets” has the meaning given in section 21(1) of TCGA 1992, but also includes sterling.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 24 paras. 4-4D substituted for Sch. 24 para. 4 (6.4.2011) by Finance Act 2010 (c. 13), s. 35(2), Sch. 10 para. 2; S.I. 2011/975, art. 2(1) (with art. 3)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in Sch. 24 para. 4A(2)(a) inserted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(3)(a); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in Sch. 24 para. 4A(2)(c) substituted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(3)(b); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "Words in Sch. 24 para. 4A(3)(a) inserted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(4)(a); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Words in Sch. 24 para. 4A(3)(c) substituted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(4)(b); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F6",
      "text": "Sch. 24 para. 4A(4A)(4B) inserted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(5); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F7",
      "text": "Words in Sch. 24 para. 4A(5) substituted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(6); S.I. 2016/456, art. 3(1)"
    },
    {
      "type": "F",
      "label": "F8",
      "text": "Words in Sch. 24 para. 4A(6)(a) inserted (with effect in accordance with art. 3(2) of the commencing S.I.) by Finance Act 2015 (c. 11), s. 120(2), Sch. 20 para. 3(7); S.I. 2016/456, art. 3(1)"
    }
  ],
  "outstanding_effects": [
    {
      "type": "word substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "inserted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "inserted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "word substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "word substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "word substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "words substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "substituted for Sch. 24 para. 4A(1)",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "words inserted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "word substituted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "inserted",
      "affecting": "ukpga/2015/11",
      "affecting_title": "Finance Act 2015"
    },
    {
      "type": "omitted",
      "affecting": "ukpga/2024/3",
      "affecting_title": "Finance Act 2024"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2007/11/schedule/24/paragraph/4A",
    "retrieved_at": "2026-10-29T09:12:51.142391+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}