Indecent Disclosure? Evaluating The Channel Islands' Disclosure Facilities

With the signing of both the HMRC Guernsey Disclosure Facility (the "GDF") and HMRC Jersey Disclosure Facility (the "JDF") and the Isle of Man having put in place similar arrangements, all three crown dependencies have now entered into memoranda of understanding ("MoU") with HM Revenue & Customs ("HMRC"). This is the next and latest step in HMRC's "No Safe Havens" anti-tax avoidance/evasion strategy which is estimated to reap recoveries of up to £1 billion in the three crown dependencies alone. Of course, HMRC's efforts are a common theme across the on-shore world, as on-shore governments seek to shift at least part of the responsibility for the global downturn (or indeed the recovery from it) at the door of so called 'tax havens'.