CH124630 | Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: calculating the penalty: potential lost revenue

The Potential Lost Revenue (PLR) used in the caculation of the enabler penalty is equal to the PLR of the person they enabled. In other words, if a person is responsible for offshore tax evasion or non-compliance this will result in a PLR. This PLR will be the PLR that forms the basis for the penalty of the enabler who helped them.

When the activity that has been enabled encompasses both offshore tax non-compliance and non-offshore (domestic) tax non-compliance, the PLR to be considered for the offshore enabler penalty should be apportioned on a just and reasonable basis that fairly reflects the lost revenue attributable to the offshore non-compliance.