Liechtenstein will be the undoubted winner as the Government ramps up its assault on tax evasion.
Tax evaders that use offshore facilities to hide income and gains from the taxman will face fines of up to 200% of the tax due from April 2011.
However, under the Liechtenstein Disclosure Facility, penalties are fixed at 10% of the tax due. This could encourage far more individuals to shift their funds to the principality.
The disclosure facility will be available until March 2015 so people have plenty of time to transfer funds from other overseas bank accounts to Liechtenstein.
Whether HM Revenue and Customs would have the resources to enforce its new powers is open to discussion. The three previous amnesties have not been the successes that HMRC thought they were going to be and so they want to hit tax evaders where it hurts – in the pocket.
More prosecutions will follow but HMRC must be certain of getting a conviction because instead of persuading evaders to disclose, publicity about not being successful with a prosecution, as in the Ken Dodds case, will make more evaders chance a prosecution rather than make a disclosure.