Calculation of the increase in the amount of income tax and capital gains tax chargeable on or by reference to offshore income, assets or activities for the purposes of section 106D of TMA 19709

Paragraphs 5, 6 and 7 must be construed as if—

a

the purpose of those paragraphs is to calculate the section 106D amount (with references to “potential lost revenue” construed accordingly);

b

those paragraphs have effect only in relation to income tax or capital gains tax chargeable on or by reference to offshore income, assets or activities (other than excluded offshore income tax or capital gains tax); and

c

for the purposes of paragraph 6, the inaccuracy were a careless inaccuracy as described in paragraph 3(1)(a)9 of Schedule 24 to the Finance Act 2007.