A6.1213 Development of offshore disclosure opportunities
In 2007, HMRC announced that as a result of having received a significant amount of information relating to offshore accounts due to the work of the Offshore Fraud Project Group (OFPG, see A6.1212), and of a series of Special Commissioners' decisions which enabled them to serve information notices1 on certain large banks, they would offer taxpayers with offshore accounts an opportunity to disclose any income and gains not previously included in tax returns.
Offshore Disclosure Facility (ODF)
The offshore disclosure facility (ODF) was an opportunity for those with an offshore account and undisclosed tax liabilities to come forward and settle their affairs with HMRC and was open to those who held or had held, either directly or indirectly, an offshore account that was in any way connected to a loss of UK tax and/or duties. 'Offshore' was defined as anywhere outside the UK and therefore included any accounts held in the Channel Islands, the Isle of Man and the Republic of Ireland. Whilst the campaign was aimed primarily at those with offshore accounts, there was a parallel facility for those with undeclared onshore liabilities to come forward. In return for a full disclosure and payment of the tax and interest due, taxpayers received a fixed penalty of 10% of the tax and NIC underpaid, with no penalty on amounts totalling less than £2,500. HMRC reserved the right, however, to open a formal enquiry on some disclosures, likely to be the larger, high profile cases,
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