PWC has reported that
HMRC held a meeting with representatives of up to 100 financial institutions on 25 September 2007 in connection with offshore evasion by UK bank customers holding offshore accounts.
HMRC's pursuit of suspected offshore evasion by UK bank customers with offshore accounts is now expanding in scope, beyond the five major UK banks targeted hitherto.
According to reports HMRC asked the financial institutions to complete a questionnaire which should enable HMRC to decide on possible TMA 1970 s20(8A) notices to enforce the supply of data on offshore accounts.
As PWC also noted though:
HMRC accepted the legal constraints faced by some banks with subsidiaries in countries with banking secrecy laws, such as Switzerland, Austria, Belgium and Luxembourg and that the Isle of Man also has laws which could impede disclosure.
There has been doubt as to whether HMRC could override foreign secrecy laws and force banks to disclose information held by a foreign subsidiary.
As the FT has noted,
The Revenue needs to find out whether information relating to offshore accounts is available, either because it is on a UK-based server or because UK bank officials are authorised to access information held abroad.
There's no doubt that if they don't the law is less clear than if they do.
But doesn't this give rise to one , obvious, point, that when bank secrecy is used to assist crime (and tax evasion is a crime) then those countries that provide it are parties to that crime, and so are those who defend the secrecy arrangements that they offer?
Try offering me an alternative explanation.
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Here is your alternative explanation. Take the example of a friend of mine.
He is a consultant with a client who has operations in 67 countries. He is constantly moving from one country to another. He stays in the countries for varying periods. He tried to follow all the rules but doing so took more time than he is awake. He needs permissions there, permits here, tax returns elsewhere, no tax returns somewhere else. On top of all that, many times he should pay tax in several countries at the same time, when for example, being resident in a country at all means being resident there for the whole year. In return for this, despite the huge sums he should pay in tax no country will pay him a pension because he is not in one country long enough to accumulate the contributions necessary to get one.
As he says, he could devote his life to campaigning against people whoi have organised the world to suit only those who live in a ‘normal’ way. My friend is not a criminally-minded person. He just wants to lead his life in his way and cannot afford to devote it to lobbying against something when our system is such that nobody listens and like all of us, he will certainly die before a just system is provided. You are right that people shouldn’t evade taxes but tax systems should be fair.