By 2016 HMRC will have full details of UK resident beneficial
owners of bank accounts, companies and trusts which are located in
Jersey, Guernsey and the Isle of Man (the Crown dependencies). They
will utilise this information to check that income and gains
arising from those assets are reflected in the UK tax returns for
those individuals. Any additional tax which arises from a failure
to have disclosed any income and gains arising from the assets will
be recovered with additional late payment interest and a penalty of
between 35% and 112% of the tax due. This is dependent upon the
location of the funds and the cooperation given and could lead to a
lengthy and intrusive enquiry.
Later this year the financial institutions within the Crown
dependencies will write to all of their clients for whom they
believe details will need to be disclosed to HMRC. They will advise
them of the disclosure in 2016 and outline the opportunity to put
any un-disclosed matters right by way
