The new disclosure opportunity being conducted by HM Revenue & Customs
has been labelled as representing an ‘unfair playing field’ for taxpayers with
onshore tax liabilities only.
Gary Ashford, national head of tax risk and dispute resolution at RSM Bentley
Jennison, said disclosing taxpayers need to ensure they submit information on
unpaid taxes offshore as well as liabilities in onshore accounts.
Wholly domestic disclosures are not within the scope of the NDO, and those
taxpayers will be subject to the standard HMRC penalty structure.
‘This could create an unfair position for those with UK only problems. It
would be better to create a disclosure opportunity for all irregularities, other
than the most serious, whether it be offshore or onshore for the period of the
NDO,’ he said.
The Chartered Institute of Taxation said the HMRC briefing refers to offshore
disclosures, but ‘omits to discuss purely onshore disclosures’. The CIoT said
its continuing to ask for this to be covered in guidance.
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