Offshore Arrangements under Siege

There is nothing new in HMRC's special interest in not to say concern about any offshore arrangements entered into by any taxpaying entity resident in the United Kingdom (UK). For years the very mention in accounts or documentation of opaque structures such as 'stiftung' or 'anstalt' was sufficient to merit fairly intense scrutiny by what was then a Somerset House specialist. What is new is the extent of international co-operation between fiscal authorities both inside and outside the European Union (EU) urged on by the finance ministers of the Group of Seven leading industrial nations and the wider membership of the Organisation for Economic Cooperation & Development (OECD). This previously unheard of degree of...