# Finance Act 2015, Paragraph 3

Extent: E+W+S+N.I.

The original penalty is for a “deliberate failure” if—
(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);
(b) in the case of a penalty within paragraph 2(b), the failure by P was deliberate (whether or not concealed);
(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).
(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;
and terms used in paragraph (d) have the same meaning as in Schedule 18 to FA 2017.

---
Source: https://www.legislation.gov.uk/ukpga/2015/11/schedule/21/paragraph/3 (the official version)
Page: https://openlegislation.uk/finance-act-2015/schedule-21/paragraph-3
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.