Offshore accounts

The First-tier Tribunal heard three cases where HMRC applied for consent to serve notices under TMA 1970 s 20(8A) on financial institutions to obtain documents about UK addresses with non-UK bank accounts with the institutions.

Financial Institution No 5 which had a branch in the EU held relevant information on its computers in the UK on some 700 individuals although following the introduction of the EU Savings Tax Directive that number was reduced to 400.

A number of people with accounts in an associated company had made disclosures where the tax loss averaged £189 320 each.

Financial Institution Nos 6 and 7 were in the same group. No 6 had branches or associated companies outside the UK and No 7 had a branch in Jersey. Current related disclosures had already yielded on average £61 671 a case.

Financial Institution No 8 had a...