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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.

Tax evasion

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

page 15