We have a case of a client who participated in the offshore disclosure facility last year and paid over tax in November 2007 on a receipt from an offshore bond.
She then received a letter in April 2008 stating:
"On behalf of Commissioners for HMRC I accept the payment submitted pursuant to your offer submitted under the disclosure reference number stated above.
This concludes the review of your discloure"
After that, she received a letter in July 2008 from her normal tax office stating 'we believe you had a receipt from a bond, can we have details etc".
We wrote pointing out the bond had alreadty been disclosed and gave the officer the offshore disclosure reference.
Having confirmed that a disclosure was made, the officer is still pursuing the matter by asking for a copy of the policy document.
I believe the terms of the offshore disclosure were that if HMRC did not query the disclosure by April 2008, the taxpayer could assume finality.
Also, the usual practice of making an 'offer' and having HMRC accept should also offer finality.
Any comments on the situation would be appreciated, and any link to the original HMRC statement regarding the April 2008 finality would be very useful (HMRC website seems to have taken everything down).
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