New disclosure facility and requirement to correct past non-compliance

The Government and HMRC have, over the last two or three years, dramatically stepped up their fight against tax evasion (which is illegal) and their attempt to discourage / penalise tax avoidance (which is legal but is the subject of negative public sentiment). There has been a particular focus on offshore matters.

The Government has announced that it will put in place a final disclosure facility for people who have not paid all of the tax which they should have done on their offshore assets; impose a “requirement to correct” past offshore non-compliance (i.e. paying less tax than is legally due); and impose tough new penalties on those who do not come forward as a result of these two measures and who are subsequently found not to have paid enough tax on their overseas income and assets.