Tax is inherently complex, and where businesses or families have international interests, it is even more so.

No matter where your operations are based, tax authorities all over the world share information, checking whether tax liabilities arise on your income and assets. The risks of simply getting things wrong and being challenged by the tax authorities have increased due to the recent explosion in data exchange. We can help you get your tax affairs in order in the face of this increasing transparency.

Global tax transparency

Several measures have been introduced in recent years that significantly increase HMRC's ability to investigate tax avoidance and evasion:

  • In 2019, HMRC published its revamped No Safe Havens strategy which focuses on a range of international tax risks and extends to companies as well as individuals and trusts.
  • Following the introduction of the global Common Reporting Standard (CRS), in 2018 alone HMRC received information about the offshore financial interests of around three million UK resident individuals and data on 5.67 million offshore accounts. This information flow from CRS will continue, prompting more investigations from HMRC. Even where CRS does not apply, it has been a strict liability criminal offence in the UK to have failed to report offshore income or gains since 2017.
  • HMRC has tax information exchange agreements with over 150 countries worldwide to request data from as well as issue information notices to persons wherever they are in the world. Beneficial ownership registers are also being introduced in several jurisdictions.
  • HMRC now has 12 years to assess additional tax in respect of offshore issues, rather than the previous four- and six-year time limits for cases involving reasonable care and carelessness. Where there is deliberate tax evasion, HMRC has 20 years to raise assessments. 
  • The standard penalties under the new offshore Failure to Correct penalty regime range from 100 and 200%, with naming and shaming or criminal prosecutions for the most heinous cases.

How we can help

Our specialist team has extensive experience of offshore-related tax disclosures. We will undertake tax health checks and identify the best approaches to regularisation.

We can:

  • deliver tax risk reviews for individuals, fiduciaries and intermediaries so that a robust framework can be maintained
  • review reporting so that any misunderstandings can be anticipated and explained
  • map an international family’s global tax position and advise on the information that will be exchanged and reported in each country
  • assist with HMRC information requests, including how these relate to international families and UK resident non-domiciled individuals.

We aim to manage the overall tax risk profile and support an ongoing positive relationship with tax authorities, resolving disputes where they arise.

Director Craig Thomson

+44 (0)20 7728 2390

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