There remains considerable uncertainty in English law regarding HMRC’s ability to use criminally obtained evidence when pursuing taxpayers in respect of their concealed offshore income.
Around four years ago news broke that HMRC had paid £100 000 to Heinrich Kieber a former data clerk to acquire details of undisclosed offshore bank accounts held by UK taxpayers at a Liechtenstein bank.
Moreover at about the same time HMRC came into possession of information from French revenue officials relating to approximately 7 000 UK taxpayers who held undisclosed bank accounts at a bank owned by HSBC in Geneva. The information had been stolen by Herve Falciani a computer specialist employed by HSBC who passed it to the French authorities almost...
