UK offshore tax non-compliance: operative dates for penalties, sanctions, offences, enabler penalties, naming and time limits (2011–2022)

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From 6 April 2011, a stricter penalties framework has applied to an individual’s tax position where non-compliance involves an offshore matter or an offshore transfer. The operative dates for the different penalties, sanctions and criminal offence measures relating to offshore tax matters are as follows:

Operative date

6 April 2011 — Section 35 and Schedule 10 to the Finance Act 2010 (FA 2010), together with the Finance Act 2010, Schedule 10 (Appointed Days and Transitional Provisions) Order 2011, SI 2011/975 — Offshore-focused penalties introduced for inaccuracies on returns, failures to notify and failures to submit returns for any tax year beginning on or after 6 April 2011 for the purposes of income tax and capital gains tax (CGT). See Practice Note: Penalties for offshore tax non-compliance—Scope of offshore penalties regime
27 March 2015 — Section 121 and Schedule 21 to the Finance Act 2015 (FA 2015), with Royal Assent on 26 March 2015 — Introduction of an aggravated penalty targeting the movement of concealed funds to sidestep international tax transparency agreements

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Web page updated on 20/05/2026

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