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Budget comment: on offshore taxation

Leolin Price CBE QC on offshore taxation

In Chancellor Darling's Budget Speech and Report on 24 March 2010 we are told about some matters affecting offshore assets or transactions which cannot be assessed until translated into provisions in the Finance Bill or other new rules. Yet they are to operate as from 24 March 2010!

His speech included a politically playful reference to 'tax information exchange arrangements' with Dominica Grenada and Belize which are ready for signature. Such agreements on the Liechtenstein model are used for the recovery of tax payable on offshore resources gains and income improperly omitted from tax returns or disclosure to HMRC. The tax recovery may be substantial; but improper tax evasion is not contemplated by those advising or considering financial arrangements which lawfully involve some offshore involvement.

Chancellor Darling threatens intensified action against any arrangement which the Government or HMRC...

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