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  3. Tax Advisor Warns Of HMRC's 'July Offensive' Against Offshore Account Holders

Tax Advisor Warns Of HMRC's 'July Offensive' Against Offshore Account Holders

by Jason Gorringe,, London

11 May 2007

HM Revenue and Customs will launch its clampdown on undisclosed tax liabilities in offshore accounts on 9 July - just 16 days after the 22 June notification deadline under its new offshore amnesty facility, warns tax advisory firm Chiltern Plc.

According to Steve Besford, head of tax investigations at tax adviser Chiltern, those with undisclosed tax liabilities connected with an offshore account who do not notify by 22 June could well find themselves under investigation any time after 9 July.

By contrast, people who notify their intention to make a disclosure before the deadline of 22 June can be assured that HMRC will not raise any enquiry into their affairs prior to the disclosure deadline of 26 November, he claims.

Mr Besford said: "9 July is the first date on which HMRC can be assured that all notifications have been processed and the appropriate 'no enquiry' signal posted to the taxpayer's computer record."

Chiltern says it is known that the offshore account information in HMRC's possession has already been 'risk assessed' using a central resource. Cases for investigation will be distributed to local offices, Civil Investigation of Fraud Offices and Special Civil Investigation Offices immediately after 9 July.

Mr Besford added: "If additional tax is found to be due as a result of these enquiries, HMRC will seek considerably higher penalties than the 10% on offer under the amnesty and may even launch criminal investigations."

In April, HM Revenue and Customs announced arrangements enabling investors with offshore accounts to disclose to HMRC any income and gains not previously included in their tax returns.

HMRC said it has recently obtained information about holders of offshore accounts from a number of banks and has obtained similar details through the European Savings Directive. The banks in question are thought to include Barclays, HSBC, HBOS, Royal Bank of Scotland and Lloyds TSB, according to reports.

For a limited period, the amnesty will allow taxpayers to come forward and make a full disclosure of all undeclared liabilities, not just those connected with an offshore account. Personal disclosures or those made on behalf of others will also be accepted under the terms of the Offshore Disclosure Facility.

A comprehensive report in our Intelligence Report series examining offshore investment, offshore stock exchanges, trusts and hedge funds is available in the Lowtax Library at and a description of the report can be seen at

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