The existing Liechtenstein Disclosure Facility was due to end on 5 April 2016 and the Crown Dependencies Disclosure Facilities for Jersey, Guernsey and the Isle of Man were due to end on 30 September 2016.
The Liechtenstein and Crown Dependencies Disclosure Facilities will now all close at the end of 2015.
In advance of the receipt of data under the Common Reporting Standard, in which the Government will invest £4 million in data analytics, a new time limited disclosure facility is being offered from 1 January 2016 to mid-2017.
It is understood that the new facility will be offered on ‘less generous terms’ than the existing facilities. In view of the criticism directed at HMRC recently in connection with the HSBC data, it seems likely the immunity from prosecution afforded under the Liechtenstein Disclosure Facility will disappear and tax geared penalties will increase.
These changes will reduce the time available to individuals and businesses to make voluntary disclosures to HMRC. Anyone that may need to take advantage of the disclosure facilities should act now to ensure that they are able to take full advantage of the favourable terms currently available.