KEY POINTS:
- HMRC's criminal clearance letters were a useful development during the offshore disclosure facility.
- Could HMRC revisit disclosed cases if further information comes to light?
- Measures that those who did not register might take.
- Steps to take relating to clients who registered with the offshore disclosure facility.
As practitioners work on submitting disclosures using the offshore disclosure facility before the deadline of 26 November 2007 one cannot help but wonder what the landscape will look like after that date. Will we see the 'thousands' of tax enquiries which people are talking about?
As readers will recall HMRC offered a short window of opportunity for those who had missed items off their tax returns to enable them to get back to the correct tax position albeit with the payment of any tax due and interest....
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