Offshore tax evaders—criminal offences
Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman
Offshore tax evaders—criminal offences

The following Corporate Crime practice note produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman provides comprehensive and up to date legal information covering:

  • Offshore tax evaders—criminal offences
  • Background to the strict liability offences for offshore tax evaders
  • What offences were created by FA 2016?
  • Who may be guilty of the offences?
  • Elements of the offences which the prosecution has to prove
  • Failing to give notice of being chargeable to tax
  • Failing to deliver a return
  • Making an inaccurate return
  • What is the relevant standard of proof?
  • Any applicable exclusions
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for corporate crime?

Background to the strict liability offences for offshore tax evaders

The government’s strategy for tackling offshore tax evasion was initially set out in HMRC’s 2014 No Safe Havens with a supplement issued in 2019. The general aims of No Safe Havens 2014 were that:

  1. there are no jurisdictions where UK taxpayers feel safe to hide their income and assets from HMRC

  2. would-be offshore evaders realise that the balance of risk is against them

  3. offshore evaders voluntarily pay the tax due and remain compliant

  4. those who do not come forward are detected and face vigorously-enforced sanctions; and

  5. there will be no place for facilitators of offshore evasion

As to the first and second aims, the Common Reporting Standard (CRS) marked 'an unprecedented step change' in its ability to tackle offshore evasion. The CRS involves an automatic and much increased exchange of taxpayer information

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