Taxes Management Act 1970 section 106E

Exclusions from offences under sections 106B to 106D

Section 106E sets out the circumstances in which a person is excluded from the criminal offences relating to offshore income, assets, and activities created by sections 106B (failing to notify chargeability), 106C (failing to deliver a return), and 106D (making an inaccurate return).

• Trustees of settlements are excluded from the offshore tax offences when acting in that capacity
• Executors and administrators of deceased persons are similarly excluded when acting in that capacity
• The Treasury has the power to create further exclusions by regulation, based on specified conditions or circumstances
• Such regulatory conditions may relate to the nature of the income, assets, or activities giving rise to the tax charge