SCHEDULES

SCHEDULE 20Penalties for enablers of offshore tax evasion or non-compliance

PART 1Liability for penalty

Appeals

12

A person may appeal against—

(a)

a decision of HMRC that a penalty under paragraph 1 is payable by that person, or

(b)

a decision of HMRC as to the amount of a penalty under paragraph 1 payable by the person.