Offshore Banks Disclosures to HMRC

In 2006, following complicated litigation relating to an information request by H M Revenue & Customs to one of the big four banks in the UK, the Courts held that the bank in the UK was liable to supply to HMRC a list of all UK residents holding accounts with one of their off-shore branches.
Following a facility in 2007 where over 40,000 people disclosed tax irregularities, HMRC decided in 2009 to allow a second similar scheme to run.
The scheme, called New Disclosure Opportunity (NDO), ran between 1 September 2009 and 12 March 2010 giving rise to a further 10,000 disclosures.
Between 2009 and 2016 the Liechtenstein Disclosure Facility (LDF) enables people with assets in Liechtenstein to declare income held overseas and pay a reduced amount of tax, and a fixed penalty of 10%. This is a good opportunity for individuals to tidy up their tax affairs, even if funds are not currently held in Liechtenstein. You can read more about the LDF below.
In 2013 the UK’s tax agreement with Switzerland meant that UK residents with Swiss bank accounts could opt to remain anonymous and have a one off tax charge taken from their accounts to cover all past liabilities. This opportunity is now closed.
If you have any offshore bank accounts or income which you consider may have given rise to UK tax that has not been paid, then we would strongly advise that you contact us at an early opportunity. There are ways to sort out overseas held funds, and we can help you through every step of this process.
Similar processes have been established for money held in other countries, but until 2016, the LDF looks like a more attractive option for many people. Contact us for more details, personalised for your circumstances.
Special evasion teams and campaigns
Since 2007, HMRC have set up new teams, overseen by SI offices, to tackle tax evasion. They are targeting specific groups of people and encouraging them to come forward and declare their untaxed income.
If you receive a letter that might indicate it is from a campaigns team, then there is a strong possibility that HMRC are holding information about you, which they expect you to disclose. Sometimes this information is incorrect, and so it is important that you get expert advice at an early stage.
The Liechtenstein Disclosure Facility or LDF?
The LDF is an HMRC approved scheme, whereby a UK tax resident with money held in a Liechtenstein bank qualifies to come under an umbrella which facilitates a disclosure that has the advantages of:
- non prosecution
- low penalties
- only look back to 6 April 1999.
The money can be transferred to Liechtenstein now, prior to disclosure and need not have been there before.
Our tax investigations team, led by Geoffrey Hollander FCA, has considerable experience in LDF’s and would be happy to meet with you to explain the process in more detail.
Most importantly however, we look after you throughout the process, making sure you understand what is happening, shielding you from HMRC and negotiating with HMRC on your behalf for the lowest amount of tax and penalties.
Handling the disclosure facilities including the LDF and the industry specific tax plans requires careful analysis and experience in handling these matters. Investigations which are undertaken by the CDF teams at SI are a highly specialised area. Cameron Baum is one of only a handful of firms in the country with relevant experience and proven success of dealing with such matters. This success was recognised in the British Accountancy Awards 2013 in the Best tax team category.
Contact us now
If you would like a free, confidential, no obligation meeting with Geoffrey, please contact us by email or phone to arrange an appointment.

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