SCHEDULES
SCHEDULE 20Penalties for enablers of offshore tax evasion or non-compliance
PART 1Liability for penalty
Reduction of penalty for disclosure etc by P
I19
1
If they think it right because of special circumstances, HMRC may reduce a penalty under paragraph 1.
2
In sub-paragraph 1 “special circumstances” does not include—
a
ability to pay, or
b
the fact that a potential loss of revenue from one taxpayer is balanced by a potential overpayment by another.
3
In sub-paragraph (1) the reference to reducing a penalty includes a reference to—
a
staying a penalty, or
b
agreeing a compromise in relation to proceedings for a penalty.