Requirement to correct offshore tax non-compliance

Under the requirement to correct (RTC) rules in F(No. 2)A 2017, taxpayers who, at the end of 2016/17, have ‘relevant offshore tax non-compliance’ must correct the position by telling HMRC about the outstanding tax due on or before 30 September 2018. The phrase ‘relevant offshore tax non-compliance’ is defined to cover undisclosed UK income tax, CGT or IHT liabilities in respect of offshore interests. The RTC regime provides HMRC with an extended period of assessment, such that where HMRC can argue the non-compliance is deliberate, it will have until April 2021 to review non-compliance that occurred in 1997. To ensure that there is an incentive to correct any offshore tax non-compliance, there are increased penalties for any failures to correct by 30 September 2018.