Peter Vaines is intrugued by a Revenue U-turn and the meaning of residency
HM Revenue & Customs have issued a statement relating to last years’ limited amnesty for undisclosed offshore accounts. It will be remembered that an opportunity arose for those with such accounts to disclose them and pay a fixed 10% penalty rather than to feel the full weight of the Revenue falling on them for lack of disclosure. The Revenue does not like to call this an amnesty because nobody is being relieved of any tax; they are just paying a limited penalty. The term off shore disclosure facility is the preferred term.
The Revenue had the advantage of a successful application to the courts for the disclosure of offshore bank accounts of the customers of a number of the major banks. This meant that those with such accounts could never be sure whether the details had already been provided to the Revenue and they ought therefore to come clean for fear of worse consequences awaiting them. The Revenue subsequently issued a statement warning that those who failed to disclose would be subject
