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Issue:
4116
/
Categories:
Comment & Analysis
, HMRC powers
, ODF
, offshore disclosure facility
, Residence & domicile
JOHN CASSIDY considers what happens now that the offshore disclosure facility registration window has closed
KEY POINTS
- HMRC expects tax from previously undisclosed offshore income from some 100 000 people.
- Dealing with investigations under Code of Practice 9.
- Does the adviser have the right experience to deal with Code 9 investigations?
- Even clients who are not domiciled in the UK should not be ignored.
- The offshore disclosure facility has been a success for HMRC.
It seems a long long time ago that HMRC won the right before the Special Commissioners to serve notices on an unnamed high street bank believed to be Barclays Bank (and four other banks subsequently) demanding various data on customers with offshore accounts or credit cards that had a connection with a UK mainland address. In fact the first case Financial Institution No 2 (SpC 536) concerning offshore accounts was heard in...
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