Tag: Penalty for tax understatement
TPG2022 Chapter IV paragraph 4.24
It is difficult to evaluate in the abstract whether the amount of a civil monetary penalty is excessive. Among OECD member countries, civil monetary penalties for tax understatement are frequently calculated as a percentage of the tax understatement, where the percentage most often ranges from 10% to 200%. In most OECD member countries, the rate of the penalty increases as the conditions for imposing the penalty increase. For instance, the higher rate penalties often can be imposed only by showing a high degree of taxpayer culpability, such as a wilful intent to evade. “No-fault†penalties, where used, tend to be at lower rates than those triggered by taxpayer culpability (see paragraph 4.28) ...
TPG2017 Chapter IV paragraph 4.24
It is difficult to evaluate in the abstract whether the amount of a civil monetary penalty is excessive. Among OECD member countries, civil monetary penalties for tax understatement are frequently calculated as a percentage of the tax understatement, where the percentage most often ranges from 10% to 200%. In most OECD member countries, the rate of the penalty increases as the conditions for imposing the penalty increase. For instance, the higher rate penalties often can be imposed only by showing a high degree of taxpayer culpability, such as a wilful intent to evade. “No-fault†penalties, where used, tend to be at lower rates than those triggered by taxpayer culpability (see paragraph 4.28) ...