You may have seen media coverage concerning HMRC's use of account holder information stolen from HSBC in Switzerland. It is now evident that HMRC has reviewed the information and has launched a concerted attack against tax evasion on the strength of it.
We have recently seen a flurry of new tax investigations under Code of Practice 9 [COP9] - Civil Investigations into Cases of Suspected Serious Tax Fraud as a consequence of HMRC being passed information on HSBC customers who have accounts in Switzerland. Investigations under COP9 are the most serious non-criminal tax investigations that HMRC undertakes. These enquiries are being led by HMRC's most elite investigators at Specialist Investigations [SI], with the recent cases originating from the Glasgow office.
The background to this initiative concerns the theft, three years ago, by an employee of HSBC, of the personal account details of 24,000 customers who held accounts in Switzerland. The customers involved were not necessarily resident in Switzerland, and it is believed that approximately 25% are either UK resident or have an exposure to UK taxation. The information was initially sold to the French and Italian tax authorities who have used it to undertake a number of investigations and recover significant sums of tax. This information has now been passed to HMRC, and HMRC is using it to ratchet up its stated objective to tackle tax evasion linked to offshore bank accounts.