UK taxpayers and associated intermediaries are having to come to terms with a harsh new environment, when it comes to tax compliance and the pursuit of tax liabilities and penalties by the UK tax authority.

H M Revenue & Customs (HMRC) is now making full use of a huge increase in information at its disposal. Some of this is obtained using its extensive information-gathering powers, but far more detailed information is often available to it via the Common Reporting Standard, data leaks and its super computer “Connect”. The UK government has also introduced a series of new rules which give HMRC the ability to impose much tougher penalties for non-compliance with UK tax obligations, even where such non-compliance is accidental rather than deliberate.

Drawing on the practical experiences of our tax and tax disputes teams in London and Switzerland and through use of case studies, we will look at a number of key issues coming out of the new regime:

  • Domicile enquiries: why are HMRC suddenly challenging so many individuals regarding their non-UK domicile? Why are individuals being challenged on their domicile even where they have become deemed domiciled under the 2017 legislation? What questions are HMRC asking and how should a client and their advisors respond?
  • How mistakes, from the simple to the highly complex, come about and how HMRC picks up on them with enquiries
  • Life after the Requirement to Correct: the new penalty regime from simple mistakes and unintentional failures through to outright concealed evasion and fraud
  • The impact of the General Anti-Abuse Rule (GAAR)
  • The risks for advisors, fiduciaries and financial institutions: penalties for enablers of defeated tax avoidance, DAC6 and the corporate offence of failure to prevent the facilitation of tax evasion.