Following meetings between the taxman and 170 private banks and investment managers last week, reports have suggested that HM Revenue & Customs might access their clients’ offshore accounts to check for unpaid tax while introducing a second

Offshore Disclosure Facility, aimed at encouraging individuals to admit they owe tax.
But advisers said that there was little or no chance of a new facility, due to problems it would cause with original disclosers.

‘HMRC has got itself into a bind, they didn’t plan ahead,’ said Baker Tilly head of tax George Bull.

According to Bull, HMRC’s original scheme had not attracted enough large-scale tax evaders because the taxman had not removed the threat of prosecution, so smaller evaders disclosed.

‘HMRC has a duty to give [tax] certainty, how could it justify a more relaxed OD?’ he added.

‘They said originally that they wouldn’t do it again,’ said PricewaterhouseCoopers tax partner John Whiting. ‘[Individuals] would have based their decision on what they were told at the time. It would surprise me if HMRC offered another “amnesty”.’

HMRC refused to rule out another disclosure facility, stating that ‘no decision had been made’.

‘Our main concern is that people only get one chance, the first facility wasn’t limited to whom could [take advantage] of it,’ said an HMRC spokeswoman. ‘It’s still under consideration,’ she added.

Around 60,000 individuals came forward during the initial amnesty to declare unpaid tax. They have until 26 November to pay what they owe to take advantage of the facility’s terms.

HMRC is chasing individuals who did not disclose before the initial cut-off of 22 June, which is believed to be as many as another 100,000 cases.