Offshore account

The taxpayer worked for a medical agency and was paid via his company. He had graduated as a doctor in India and arrived in the UK in 1987 via Nigeria where he had been employed. His wife came to the UK in 1991.

He learned in 2007 of HMRC’s amnesty for those with offshore accounts and instructed his advisers to declare accounts he had opened in 1988 and on which interest of almost £60 000 had been paid.

The accountants told the Revenue that the taxpayer and his wife had assumed they would not have to pay UK income tax because neither of them was domiciled.

The tax department began an investigation and found that payments of earnings had been paid directly into the offshore account which had added the taxpayer’s company as an account holder.

HMRC claimed the taxpayer and his wife had under-declared earnings and...