What taxpayers with Swiss accounts need to know about HMRC’s disclosure pack

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What taxpayers with Swiss accounts need to know about HMRC’s disclosure pack

10 Feb 2015

Over the last year or so, HMRC have been contacting taxpayers with Swiss bank accounts who authorised their banks to disclose their details, rather than have a one-off charge applied under the UK Swiss Tax cooperation agreement. When contacted, taxpayers had the choice of stating that there were no undeclared taxes, making a disclosure via the Liechtenstein Disclosure Facility (LDF), or agreeing to make disclosure outside of the LDF.

Having advised on in excess of 300 disclosure cases, our experience is that the majority of taxpayers elected to disclose through the LDF to take advantage of its beneficial terms. However, some taxpayers have elected to make disclosure without going through the LDF, either where the LDF did not offer beneficial tax treatment, or where the tax due was so small that the cost of using the LDF outweighed the benefit.

Our experience is that those clients electing to make a disclosure outside of the LDF have not since been contacted by HMRC, despite having confirmed they wished to make a disclosure many months ago. However, HMRC (we believe having been overwhelmed by the volume of disclosures made) have finally issued a disclosure pack allowing those taxpayers to disclose their accounts and pay the tax, interest and penalties now due.

The disclosure pack runs to some 36 pages and we believe that advice from someone experienced in making disclosure of undeclared taxes relating to offshore assets will need to be consulted in order to complete the disclosure process.

For further information on disclosing Swiss bank accounts or those from other jurisdictions call Paul Bricknell on 0161 832 3434 or contact us.

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