Iberian interest

For a number of years we have acted on behalf of a UK taxpayer. He is married to a Spanish national and they have a child.

His wife claims to have been non-domiciled for the period before April 2008 but UK-domiciled from that date although we suspect that no formal claim i.e. on form DOM1 has been made.

She has an offshore bank account but interest from this source has never been remitted to the UK; however now that she claims to be UK-domiciled she wishes to declare the interest arising from this source.

If her claim for non-domicile until April 2008 is acceptable this would mean filing a 2008/09 tax return and including the interest for that year only.

However if her claim for non-domicile fails then she would need to declare the interest for a number of years and this...