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JOHN CASSIDY comments on HMRC's use of intervention letters and the discovery provisions for those who did not use the offshore disclosure facility
KEY POINTS
- HMRC's ODF follow-up procedure.
- Should there be a presumption of guilt?
- Is 'discovery' being properly used?
- Non-residents and non-domiciles are caught in the net.
- Are ODF investigations flawed in implementation and approach?
In my article In hot pursuit I commented on how HMRC proposed to tackle the thousands of individuals who did not use the offshore disclosure facility (ODF) but who are known to have held overseas bank accounts. (In this context 'offshore' means 'overseas' — it is not confined tax havens or low tax jurisdictions but equally embraces the EU and other developed countries.)
I went on to explain the system built around interventions and discovery that had been developed by HMRC to this end. A concern at that time was the underlying presumption within the system...
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