The Chartered Institute of Taxation has been sent a sample of the letter, which warns that anyone who fails to reply may face a detailed tax, “or in some cases” a criminal investigation by HMRC.
The disclosure agreement has so far failed to bring in the anticipated proportion of the £3.2bn it was projected to raise.
HMRC’s specialist investigations offshore coordination unit sets out sets out three options in the letter. Certificate A relates to those who have no outstanding UK tax liabilities; certificate B covers off those who are already registered for the Liechtenstein disclosure facility (LDF); and certificate C is the one for those have outstanding liabilities but are not using LDF.
In October last year the UK Government’s public accounts committee held a session in which HMRC admitted that it had raised £440m so far that year and £782m in total, and said the forecasts had been “inaccurate”.
This was in part due to the Swiss banks’ culture of secrecy, tax assurance commissioner Edward Troup said, and while on a visit to Switzerland, HMRC conveyed its concern about the amounts they were receiving to the Swiss representatives.
18,000 names had been given to HMRC by the Swiss authorities and letters had been sent to 9,000 of those, Troup told MPs at that time.
In November 2012, HM Revenue & Customs shuffled its team of agents who handle Liechtenstein Disclosure Facility disclosures, to the frustration of some specialist tax experts.
