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PwC: Tax Investigations Newsflash
HMRC set to investigate UK taxpayers with offshore HSBC accounts
Earlier this year, the theft of data from HSBC's private bank in Switzerland was widely reported in the British press. When the story first broke there was much interest in how this significant theft of data could have taken place, but gradually over time interest in the story has waned. During this time, however, HMRC has continued to focus attention on the information received from its French counterpart and we understand from well placed sources in HMRC that advanced preparations are underway to commence investigations into the affairs of those UK taxpayers who are suspected of evading their UK tax liabilities. In recent weeks, PwC has been approached by a number of individuals who held HSBC accounts requesting advice on how to manage the expected approach from HMRC querying their historic tax affairs. As with any form of disclosure, cooperation is key, in this instance perhaps more so as we understand the information held by HMRC is unusually detailed compared to previous data leaks. For individuals in this position who are looking to make a voluntary disclosure in advance of an approach by HMRC, the Liechtenstein Disclosure Facility ('LDF') presents an attractive opportunity for trying to manage the process of any enquiry and bringing matters to a resolution in a cost and time effective manner. The usual LDF qualification criteria continue to apply for all individuals considering making a disclosure under this route, however, it should also be noted that if the individual was contacted by HMRC under a previous disclosure facility and decided against making a disclosure at that point, the guaranteed 10% penalty will not apply and a 20% penalty will instead apply for the tax years to 5 April 2009. For tax years after this date the penalty will based on the minimum level appropriate under UK legislation for deliberate behaviour. If you would like to know more about this topic or have a client who needs help, please call 0800 328 8215 anytime or your regular PwC contact. Our tax investigations e-newsflashes bring key developments to your attention as they happen. If you would like to discuss anything covered by this newsflash or any tax investigation issue please call our 24 hour helpline on 0800 328 8215 or email tax.investigations@uk.pwc.com. Visit our website:www.tax-investigations.com.
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