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Last week, HM Revenue & Customs publicised that it was to "target UK residents and organisations holding Swiss bank accounts with the HSBC in Geneva who may not have reported all their income and gains to HMRC".

Also, that it had "begun criminal and serious fraud investigations into more than 500 individuals and organisations holding these accounts".

Whilst the official version of the press release simply reported that it was acting on information received last year under a tax treaty, it seems that the original source was a disgruntled ex-employee of HSBC in Geneva, whom the BBC reports to have stolen the information and then passed it to the French tax authorities - who then passed it on to HMRC.

For those of the 6,000 not already under investigation, HMRC will be offering a "window of opportunity" for them to contact HMRC and disclose all their tax liabilities. If they fail to do so, HMRC is threatening to open a formal investigation into their affairs, which could include a criminal investigation or result in penalties of up to 200% of the tax unpaid, under the new regime for offshore evasion.

LDF Again?

The official press release quotes Dave Hartnett as saying, “This is not an amnesty." Yet the same press release also observes that many of the 6,000 will have been able to avoid  the threat of criminal prosecution, etc., by availing themselves of the Liechtenstein Disclosure Facility (LDF) - a tax amnesty - which promises that those who use it will broadly escape criminal charges unless the funds in question are themselves derived from (non-tax) criminal activity.

For the official version of the press release - and a helpful link to the Liechtenstein Disclosure Facility  - see Revenue Targets 6,000 Swiss Bank Accounts