When I was younger and fitter I used to play a bit of rugby union. I played in the backs and when the ball came out to us, we had one job to do, and that was to cross the ‘gain line’. This would ensure that the pack was moving forwards, remained on the front foot and retained the advantage. In the game that is HM Revenue & Customs (HMRC) versus the offshore industry there have been a number of developments in recent years and it is now HMRC which is undoubtedly in the ascendancy.
There are three reasons for HMRC’s success. The first is that legislation and documentation has been tightened up. Second, HMRC has enjoyed some success in the courts and, third, there has been a significant increase in the amount of funds made available to HMRC to combat tax avoidance.
