Last year’s amnesty for offshore account holders with unpaid liabilities has had mixed results. Andrew Watt looks at how similar schemes can be managed more effectively in the future

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 2007