We have now become familiar with the Liechtenstein Disclosure Facility and, in traditional fashion, 3 more have come along at once - Jersey, Guernsey and the Isle of Man. They are all very similar (and the disclosure pack whereby the disclosures are made seems identical to the LDF) but none of them have the automatic exemption from criminal prosecution that is a feature of the LDF. However, HMRC do confirm in their FAQs that they will not start a criminal investigation for a tax related offence if a full and accurate disclosure has been made.
All the recognisable features are there in these new disclosure facilities - a 10% penalty (but only up to 2007/8) and higher penalties for subsequent years - and complete closure in respect of years prior to 1999.
These facilities are seriously advantageous and although they require full disclosure of all income and gains (and a full statement of worldwide assets), that can hardly be objectionable for anybody who has misbehaved and now wants to put their affairs in order.
Having regard to the amount of information which we are told is flowing around, and therefore available to HMRC, it must be highly likely that anybody seeking to conceal income in the Islands will get a tap on the shoulder before too long. That would disqualify them from the benefits of the disclosure facilities the consequences of which could prove fearfully expensive.