Paragraph 14
(1)
The penalty payable under paragraph 1 is 200% of the offshore PLR attributable to the uncorrected offshore tax non-compliance (subject to any reduction under a provision of this Part of this Schedule).
(2)
In this Part of this Schedule “the uncorrected offshore tax non-compliance” means—
(a)
the relevant offshore tax non-compliance, in a case where none of it is corrected within the RTC period, or
(b)
so much of the relevant offshore tax non-compliance as has not been corrected within the RTC period, in a case where part of it is corrected within that period.