SCHEDULES
SCHEDULE 22Asset-based penalty for offshore inaccuracies and failures
PART 2Amount of penalty
9Special reduction
1
If HMRC think it right because of special circumstances, they may reduce the standard amount of the asset-based penalty.
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 over-payment by another.
3
In sub-paragraph (1) the reference to reducing a penalty includes a reference to—
a
staying a penalty, and
b
agreeing a compromise in relation to proceedings for a penalty.