The department said last week that it would be analysing the data it has from
one financial institution, thought to be Barclays, through its local area
offices. Enquiries will be submitted, investigations pursued and tax collected.
That in itself could take a while, and only once it is complete, HMRC
implied, will other banks be pursued.
HMRC looks like having a strong case to get the same information out of the
The number of accounts gathered in the most recent disclosure notice exceeded
the number of people who fill in the foreign income sections of their tax
returns. And the tax regained from various related investigations was compelling
enough to justify a wider information haul, the commissioners said.
Whether or not the taxman can marshal the same information in relation to
other banks may prove the sticking point.
One problem HMRC faces is whether the banks will play ball. In a statement
that implied this is no straightforward matter, Lloyds TSB said last week that
it would make any decision with regard to client confidentiality and to its
While that may not mean the high street bank would fight it all the way, it
is putting down the terms within which it would resist disclosure.
So if it went all the way, how long would that take? In the Barclays case,
the first discussions took place in September 2004. The notice was issued
earlier this year, meaning a rough time frame of about 15 to 18 months.
That wouldn’t necessarily be the case for others, said Tom Rowbotham of
Deloitte: ‘I would expect HMRC to approach financial institutions in order to
discuss the position to try and facilitate the process.’
Some could portray the disclosures as more of a ‘fishing’ expedition, not
allowed under disclosure rules, than others.
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