{
  "url": "https://openlegislation.uk/finance-act-2015/schedule-21/paragraph-3",
  "json_url": "https://openlegislation.uk/finance-act-2015/schedule-21/paragraph-3.json",
  "legislation": "ukpga/2015/11",
  "legislation_title": "Finance Act 2015",
  "legislation_url": "https://openlegislation.uk/finance-act-2015",
  "path": "schedule/21/paragraph/3",
  "kind": "paragraph",
  "number": "3",
  "heading": null,
  "text": "The original penalty is for a “deliberate failure” if—\n(a) in the case of a penalty within paragraph 2(a), the inaccuracy to which it relates was deliberate on P's part (whether or not concealed);\n(b) in the case of a penalty within paragraph 2(b), the failure by P was deliberate (whether or not concealed);\n(c) in the case of a penalty within paragraph 2(c), the withholding of the information, resulting from the failure to make the return, is deliberate (whether or not concealed).\n(d) in the case of a penalty within paragraph 2(d), P was aware at any time during the RTC period that at the end of the 2016-17 tax year P had relevant offshore tax non-compliance to correct;\nand terms used in paragraph (d) have the same meaning as in Schedule 18 to FA 2017.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 21 para. 3(d) and words inserted (with effect in accordance with Sch. 18 paras. 2-13 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 18 para. 27(3)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2015/11/schedule/21/paragraph/3",
    "retrieved_at": "2026-10-29T09:07:01.784220+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."
}