Paragraph 27

Schedule 21 to FA 2015 (penalties in connection with offshore asset moves) is amended as follows.

In paragraph 2 (original penalties triggering penalties under Schedule 21) omit “and” after paragraph (b) and after paragraph (c) insert

“, and

(d)

a penalty under paragraph 1 of Schedule 18 to FA 2017 (requirement to correct relevant offshore tax non-compliance).”

In paragraph 3 (meaning of deliberate failure) after paragraph (c) insert—

“(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. ”

In paragraph 5 (meaning of “relevant time”) after sub-paragraph (4) insert—

“(5)

Where the original penalty is under paragraph 1 of Schedule 18 to FA 2017, the relevant time is the time when that Schedule comes into force.”