The Regulations appoint 1st April 2017 as the day on which the amendments to section 94 of the Finance Act 2009 (c. 10) made by section 164 of the Finance Act 2016 (c. 24). Section 94 gives the Commissioners for Her Majesty’s Revenue and Customs the power to publish information about persons subject to “relevant tax penalties” as defined by that section. The amendments made to section 94 include adding penalties relating to offshore matters and offshore transfers as “relevant tax penalties” and other consequential amendments.