using deep in the money options (DITMOs). The change will apply
to options entered into after 24 November 2015 and exercised
after 22 March 2016.
The government will consult on new sanctions on those who
repeatedly and deliberately participate in the ‘hidden economy’,
including penalties and monitoring of repeat offenders.
As previously announced, there will be a new criminal offence
that removes the need to prove intent for the most serious cases
of failing to declare offshore income and gains.
Also as previously announced, civil penalties for deliberate
offshore tax evasion will be increased. There will be a new
penalty linked to the value of the asset on which tax was evaded.
New civil penalties will apply to those who enable offshore tax
evasion. There will be a new legal requirement to correct past
offshore non-compliance within a defined period, with sanctions
for those who fail to do so.
General anti-abuse rule
There will be a new penalty of 60% of the tax due to be charged
in all cases successfully tackled under the general anti-abuse rule
(GAAR). The GAAR procedure will be changed to improve its
ability to counter marketed avoidance schemes.
16 MARCH 2016