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PHIL BERWICK considers issues arising under the new disclosure opportunity and whether HMRC learnt any lessons from the offshore disclosure facility
KEY POINTS
- Have lessons been learnt from the ODF?
- What about domestic disclosures?
- Is an acceptance deadline required?
- Should there be immunity from prosecution?
- The need for an effective publicity campaign.
- Potential penalty problems.
HMRC’s new disclosure opportunity (NDO) is almost upon us. Before considering the NDO it’s worth having a brief recap on HMRC’s previous dedicated disclosure process the offshore disclosure facility (ODF) which was held in 2007.
Practitioners would quite reasonably expect HMRC to learn lessons where appropriate from the ODF and improve the process for any subsequent facility.
When the ODF was originally mentioned it was estimated that the process would generate revenue in the region of £1 billion. In the end the ODF brought in £400 million...
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