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The Persuaders
Key points
- The terms of the Liechtenstein disclosure facility were generous but closed in December 2015.
- The worldwide disclosure facility was introduced in advance of the first exchange of data under the common reporting standard.
- Taxpayers could disclose offshore sources of income under the requirement to correct legislation until 30 September 2018.
- Penalties under the failure to correct regime can be up to 200% of the tax due.
- Consider requesting the code of practice 9 process to gain immunity from a criminal investigation.
To consider why clients should voluntarily disclose unpaid tax from offshore assets it is worth understanding how we have got to where we are. Fourteen years ago HMRC undertook ground-breaking work on obtaining details of overseas bank accounts for customers connected with a UK residential address by issuing notices to five high street banks. It then launched the first of the disclosure facilities for...
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