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Revenue watch: Offshore climate change

Richard Clarke and Jessica McLellan explain why any taxpayer with current cross-border activities should be aware of the new penalty regime for offshore funds

It has been clear that in recent years HMRC has been moving towards tackling offshore evasion and avoidance through a number of different approaches. Campaigns such as the Offshore Disclosure Facility the New Disclosure Opportunity and the Liechtenstein Disclosure Facility have been accompanied by a drive to obtain third party information through ‘unknown class’ notices from financial institutions with a UK footprint. Due to growing success in serving such notices HMRC have obtained a body of both personal and corporate bank information which they have recently indicated will be ready by autumn 2010 for risk assessment and to commence enquiries.

These movements on the domestic front have occurred against a backdrop of a renewed global focus on reducing tax revenues lost to offshore...

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