The government will legislate for a new criminal offence for corporations that fail to take adequate steps to prevent tax evasion. HMRC has confirmed that in addition to the new criminal offence, the government will introduce a penalty for offshore evasion based on the value of the asset on which tax was evaded. A further criminal offence is to be legislated for that removes the need to prove intent where a large amount of tax has not been paid on offshore income and gains.
However, HMRC may face challenges should they decide to prosecute overseas firms that played a role in allowing the evasion of UK taxes to take place, as it would be very hard for the UK to force an overseas company to turn up in a UK court to face prosecution; you can’t extradite a company.