A taxpayer will be guilty of an offence under sections 106B, 106C or 106D of the Taxes Management Act 1970 (c. 9) (“TMA 1970”) in respect of certain failures to comply with sections 7 or 8 of the TMA 1970 for the year of assessment commencing on 6th April 2017 or a subsequent year where, as a result of the failure, the taxpayer does not tell the Commissioners for Her Majesty’s Revenue and Customs (“HMRC”) that the taxpayer is liable to pay an amount of income tax or capital gains tax chargeable on or by reference to offshore income, assets or liabilities (“relevant tax”). There is no offence under those provisions if the total of the relevant tax unreported to HMRC for the year of assessment in question does not exceed the “threshold amount”. Regulation 3 specifies the threshold amount as £25,000. Regulations 4 to 9 set out the means of determining whether the threshold amount has been exceeded.