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United Kingdom: Ruling Requires British Offshore Accounts Be Revealed

(Aug. 25, 2009) A recent ruling by the Special Commissioners, the tax courts of the United Kingdom, requires over 300 UK and foreign banks to disclose the details of 500,000 British taxpayers' accounts. The UK's tax authority, HM Revenue and Customs (HMRC), estimates that this may enable them to recover over £500 million (approximately US$800 million) over the next four years. To encourage offshore account holders to come forward, HMRC is offering an amnesty, known as the New Disclosure Arrangement, from September 1, 2009, until March 12, 2010. It allows individuals with unpaid taxes from offshore accounts to settle at a reduced, ten percent penalty. Those who do not use this arrangement can face a penalty of from 30 to up to 100 percent, as well as possible prosecution. (HM Revenue and Customs, Offshore Disclosure Initiative Launch, July 28, 2009, available at
; HM Revenue and Customs, Banks to Disclose All Offshore Account Information to HMRC, NEWS DISTRIBUTION SERVICE, Aug. 12, 2009, available at
; Michael Herman & Gráinne Gilmore, Taxman +wins Right to See Details of 500,000 Offshore Bank Accounts, TIMES (London), Aug. 13, 2009, available at