I am reproducing the discussion between Dave Hartnett, the Permanent Secretary for Tax at HMRC who is rather high-profile at the present time, and John Whiting and Gary Ashford of the Chartered Institute of Taxation (CIOT).

I have numbered the paragraphs (1 through to 38) and whilst the New Disclosure Opportunity (NDO) has expired, to all intents and purposes, the Liechtenstein Disclosure Facility (LDF) that Dave Hartnett comments on is still open of course.

It is said that Liechtenstein has received £800m from the European community funds as, presumably, an incentive to be more open in their taxation policies.

This was the case where someone actually stole the records from one of the Liechtenstein banks and was paid £100,000 by HMRC for passing on the information to them.

Whether that was morally right or not, HMRC have still used the information received, or in actual fact bought, from the person who stole the documents from the Liechtenstein bank and it may give some incentive for other people throughout the world to act in a similar way.

It’s a strange old world when what appears to be a crooked venture is condoned by the likes of HMRC.

One must not forget one matter and that is that it is not an offence to have an overseas bank account. Providing, if interest is received, it is declared on one’s Tax Return then so be it, it is perfectly alright. But if the money deposited is ‘non-kosher’ money then one can have problems.

Anyway, do read and pay particular attention to paragraphs 11 (referring to the Liechtenstein venture), 26, 29 and 30.

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