Forbes Dawson Tax Bite – HMRC letter to UK persons with Swiss Bank Accounts

In the past few weeks, HM Revenue & Customs (“HMRC”) has issued letters to thousands of UK resident holders of Swiss bank accounts and investments.

HMRC’s letters ask account holders to formally certify either that they have no UK outstanding UK tax liabilities, or that they will be making immediate full disclosure of such liabilities to HMRC.

However, the wording of HMRC’s Certificates is very widely drawn, effectively asking for confirmation that all UK taxes have been paid, not just those in relation to Swiss accounts/investments. Great caution should be taken when responding, as false statements may result in prosecution.

Those who have not paid all of their UK taxes need to make their disclosure quickly or HMRC will start their own investigations, which will result in much greater penalties being charged, and possibly even in prosecution.

For many, making disclosure via The Liechtenstein Disclosure Facility (“LDF”) is likely to be beneficial, as this offers favourable terms (e.g. significantly lower penalties and immunity from prosecution).

We would be happy to answer any queries regarding HMRC’s letters and how to respond, and/or in relation to the LDF or other disclosure options.

Tax Bites are a fortnightly article featuring simple updates about key tax opportunities for other professional colleagues and clients.  For further details, contact the author or your usual Forbes Dawson contact via our ‘Contact Us’ page.




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