Private client: Time for transparency
There can be any number of legitimate reasons why an individual, or indeed a company, might want a bank account in an offshore jurisdiction. But as far as HM Revenue and Customs (HMRC) is concerned there is only one explanation: to facilitate tax evasion. It was this view which led to the Offshore Disclosure Facility (ODF) - frequently referred to as an amnesty - which was announced by HMRC in April 2007There were two brief and distinct stages to the disclosure process. Those who held, or had held, an offshore account were given until 22 June, 2007 to notify HMRC of their intention to make a disclosure of unpaid liabilities. The deadline for making a detailed disclosure was 27 November, 2007, by which time only 45,000 of the 62,000 who made an initial notification had come forward. A significant proportion of those who made disclosures were not customers of the banks approached by HMRC, but other banks which had been alerted by the publicity given in the press to the ODF. Given that HMRC had received 400,000 pieces of information relating to some 260,000 bank customers from the five retail banks which had been served with information notices under s20 (3) Taxes Management Act 1970, one wonders how it is able to declare itself satisfied with the conspicuously small numbers making disclosures.
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