SCHEDULES

SCHEDULE 18 U.K. Requirement to correct certain offshore tax non-compliance

PART 2 U.K. Amount of penalty

Reduction of penalty for disclosure etc by person liable to penalty U.K.

17 (1) If they think it right because of special circumstances, HMRC may reduce a penalty under paragraph 1. U.K.

(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.