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HMRC is going after those offshore account holders who did not use the offshore disclosure facility. JOHN CASSIDY examines how the department will do this

KEY POINTS

  • HMRC will be opening formal enquiries
  • Providing an explanation or making a disclosure
  • HMRC's action if no response is received
  • The possible professional response
  • What about those who do not receive a letter?

Much has been written about the 2006 trial of new types of tax enquiries — collectively known as 'interventions' — most of it not complimentary of HMRC's pilot.

I do not propose to reiterate or summarise what has already been said in that respect. In this article I will concentrate on how such interventions and HMRC's current push on offshore bank accounts fit together.

Readers will no doubt be aware of the offshore disclosure facility (ODF) which was unveiled last year to facilitate disclosure of previously undeclared income and gains primarily linked to overseas bank accounts.

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