Consultation outcome

Helping taxpayers get offshore tax right – summary of responses

Updated 20 July 2022

1. Introduction

1.1. This document summarises responses to the discussion document ‘Helping taxpayers get offshore tax right’ published on 23 March 2021.

1.2. HMRC is grateful to all who responded or participated in meetings/workshops. Some respondents included comments on the discussion document ‘Collecting and preventing international tax debt’ and these are set out in a separate response document also published today.

Background

1.3. The discussion document was published as part of the government’s ‘No Safe Havens 2019’ offshore tax compliance strategy.

1.4. The ‘No Safe Havens 2019’ strategy sets out how HMRC will tackle offshore non-compliance through three areas of focus, leading internationally, assisting compliance and responding appropriately. The strategy emphasises that HMRC should consider the compliance process from beginning to end, from taxpayers understanding their tax obligations to paying the correct amount of tax due. The Helping taxpayers get offshore tax right discussion document predominantly focussed on the assisting compliance strand of the strategy.

1.5. The discussion document explored the causes of common errors made by taxpayers and offered initial ideas on how we might address those issues. A key approach of the assisting compliance strand of the No Safe Havens 2019 focuses on using data to assist with compliance. Data can be used to create prompts on Self-Assessment tax returns, which removes opportunities to make mistakes, or data can be shared directly with taxpayers early on in the self-assessment process to prevent non-compliance before it happens. Another approach explored in the discussion document and in No Safe Havens 2019 is the use of education and communications to raise awareness of taxpayers’ offshore tax obligations.

1.6. Additionally HMRC continues to explore innovative measures to assist compliance and considers ways to make tax easier to pay. Where HMRC intervenes, it will use an approach that is appropriate and proportionate to the tax at risk and taxpayers’ behaviour.

1.7. HMRC held five workshops with a cross-section of interested parties in May 2021 to stimulate thought and discussion in advance of stakeholders sending in formal written responses to the discussion document. Separately, HMRC also met with representatives from two large professional services firms, KPMG and PricewaterhouseCoopers LLP (PwC).

1.8. A total of 24 written responses were received. These came from:

• 8 representative bodies
• 12 professional advisors
• 4 individuals

1.9. HMRC also received 54 responses, through meetings, workshops and a survey. These came from:

• 4 representative bodies
• 25 professional advisors
• 25 individuals

1.10. A full list of the respondents, excluding individuals, is provided at Appendix A.

1.11. Chapter 2 sets out the questions posed in the discussion document, summarises what respondents told us and provides a government response. Chapter 3 then provides more detail on next steps and how HMRC plans to take this work forward.

2. Responses

2.1. The discussion document asked for views on new, innovative measures to make it easier for taxpayers with non-UK income and gains to declare the right amount of tax first time. Comments were invited on:

• the causes of offshore non-compliance
• the possible approaches suggested in the document
• any further ideas to improve offshore tax compliance

2.2. The government has considered these responses and will take them into account as it continues to implement its long-term ‘No Safe Havens 2019’ strategy. government responses in respect of individual questions asked in the discussion documents are below.

2.3. There were four overarching questions asked in the discussion document. The first questions were based on the following factors that might contribute to non-compliance:

• not being aware of offshore tax obligations
• guidance and communications relating to ‘offshore income’ not being relevant or clear
• reliance on anecdotal evidence or out-of-date advice
• not asking for help and support until the tax return is due

Question A: Do you agree that the factors set out in paragraph 1.9 cause offshore non-compliance?

Question B: Are there other factors that we should address to improve offshore compliance?

Question C: Do you consider the possible approaches suggested in this paper would be effective to help ensure offshore tax compliance?

Question D: What further ideas do you have to help taxpayers get their offshore tax right?

2.4. Respondents broadly agreed that the factors referred to in question A were those that contributed to offshore non-compliance. Most respondents cited the complexity of legislation concerning the taxation of non-UK income, gains and assets as a contributing factor to non-compliance. Further comments on how to address non-compliance and help taxpayers get offshore tax right are set out later in this paper.

2.5. Most respondents who gave further suggestions on how to tackle issues raised (question D) suggested variations on the solutions offered in the discussion document. These will be explored in more detail in the relevant section.

Government response

2.6. The government are pleased that respondents considered the suggestions in the discussion documents to be sensible. These suggestions are in line with the strategic objectives of ‘No safe havens 2019’.

Using data to promote offshore tax compliance

2.7. The discussion document asked for comments on how HMRC can improve compliance and prevent non-compliance by using data.

2.8. HMRC currently receives data on non-UK income through Automatic Exchange of Information (AEOI) with other tax authorities. The data comes from a variety of sources including the Common Reporting Standard (CRS) and the UK-US intergovernmental agreement relating to Foreign Account Tax Compliance Act (FATCA).

2.9. The broad idea discussed was to use data earlier in the registration and self-assessment process to help taxpayers get offshore tax right the first time. This was in the context of HMRC having significant success in recent years in using data to target and nudge taxpayers to declare the correct income.

Helpful information for taxpayers

2.10. The discussion document suggested a number of approaches including sending reminders to taxpayers at key points in the taxpayer journey, providing agents with information HMRC holds on their clients’ offshore income or assets, and providing data to help people manage a deceased person’s estate.

2.11. To explore how data could be used, the discussion document posed the following 3 questions:

Question 1: How do you think HMRC could best use offshore data to promote offshore compliance and help taxpayers get offshore tax right first time?

Question 2: How do you think HMRC could best use offshore data to stop errors from happening?

Question 3: Should additional safeguards apply to ensure taxpayers’ rights are protected if HMRC use offshore data in new ways as set out in paragraph 2.9?

2.12. Most respondents thought sharing data would be useful. Agents highlighted that it would help in conversations with taxpayers when preparing a return if this information was known.

2.13. However, other respondents highlighted the need for robust safeguards if data is to be shared. The safeguards suggested included ensuring information remains secure and confidential by using data encryption; authentication by password and appropriate back up procedures, updating form 64-8 and COMP1 forms, to explicitly ask taxpayers’ consent to HMRC sharing data with agents; and that direct sharing of data should only occur with the consent of the taxpayer. The 64-8 allows customers to authorise agents or accountants to deal with HMRC on their day-to-day matters. A COMP1 allows a taxpayer to temporarily appoint a tax advisor during a compliance check.

2.14. All respondents that answered these questions agreed that reminding taxpayers about assets held outside the UK, through correspondence to agents or directly to taxpayers themselves was worthwhile. There were several responses that offered thoughts on how best to do this, including:

• HMRC should advertise offshore penalties more in correspondence in advance of returns being finalised
• HMRC should suggest taking appropriate professional advice in any communication
• taxpayers should be able to contact HMRC and seek assistance before filing, as well as being able to provide additional explanations in disclosures where appropriate (for example, if they are advised by professionals that there are no taxes to declare)
• respondents agreed that there would be benefit to HMRC sharing data either directly or via a prompt as early in the process as possible, to allow agents to make sure returns are complete and accurate. Additionally, respondents agreed with the bullet points listed in paragraph 2.9 of the discussion document as areas where sharing would be helpful

Government response

2.15. The government notes that respondents agreed with the points outlined in paragraph 2.9 in the discussion document, in particular that it would be of benefit to share data directly or via a prompt. A prompt in this context is any way in which HMRC contacts a taxpayer to suggest they consider whether tax may be due because of certain income or assets they hold or receive. This could be via a letter through the post, via a message appearing on screen while completing a self-assessment return, or any other method.

2.16. The government recognises that some agents would like data held by HMRC shared directly with them, when appropriate and if clients give consent. However, while the general consensus among agents was in favour of this, proper safeguards would need to be in place and careful consideration of data security and confidentiality would be required before this idea can be taken forward.

2.17. The government acknowledges respondents’ suggestions concerning the use of data to prevent errors occurring in the first place. In response to these suggestions, the government is considering a pilot project where data received through AEOI will be shared with taxpayers. AEOI agreements are made between the UK and other countries which allow the exchange of information between tax administrations of different countries. The purpose of sharing this data is to remind taxpayers that they have assets outside the UK and to prompt them to register for self-assessment and declare the relevant income and gains to HMRC. By using this data in an ‘upstream’ way, the pilot would raise awareness of taxpayers’ responsibilities and help them to declare the correct amount of tax the first time. A pilot would allow HMRC to evaluate how successful this approach is before any decision is made about adopting more widely.

Helpful information from taxpayers

2.18. The discussion document also explored whether HMRC would be better able to provide help to taxpayers, and focus its compliance efforts, if taxpayers provided more data to HMRC about the non-UK income they are declaring.

2.19. The data would include a breakdown of non-UK income declared on a taxpayer’s tax return, for example providing information on non-UK bank accounts. This would help HMRC reconcile discrepancies between data received from other jurisdictions (almost always for a calendar year) and the amounts declared on tax returns which are for the UK tax year ending on 5 April. This reconciliation would help HMRC improve its assessment of risk and prevent taxpayers from receiving unnecessary enquiries. Two questions were included on this topic:

Question 4: Do you think making the changes to the data and information collected through the foreign pages, as set out in paragraph 2.14, would be helpful?

Question 5: What other areas are there where it would assist tax agents if it were made mandatory for their clients to provide HMRC (and hence the agent) with details that are not currently required in a self-assessment return?

2.20. Most responses to these questions were of the view that there is little need to increase the amount of data that HMRC collects through the tax return or elsewhere. The responses made a number of points:

• issues with the quality of data and matching current data should be solved before looking for other sources of data
• additional resource to analyse tax affairs would be a better investment than collecting mass, potentially low-quality data
• some had the view that additional data would not prevent discrepancies due to taxpayers being taxed on the remittance basis

2.21. Other respondents had the view that collecting the additional information would be reasonable if there were minimum thresholds for the additional information or supplying it was optional rather than a requirement. Some respondents agreed that it would be useful if they disclosed additional information, for example the relevant jurisdiction and/or name of the financial institution, when declaring income and gains.

2.22. During discussions at workshops, as well as in many of the written responses, the view was expressed that if HMRC has difficulty matching international data to tax returns, due to a mismatch between the UK tax year and the calendar year (under which most international data is shared), then the best option would be to change the UK tax year to match the calendar year. Respondents argued that this would benefit agents as they would not have to reconcile different accounts when completing returns and would help HMRC as we would be able to more easily match international data received to the taxpayers’ return.

Government response

2.23. The government acknowledges that most respondents remain unconvinced of the need for HMRC to collect more data through the self-assessment return.

2.24. The government believes there is a potential benefit if HMRC receives additional data from taxpayers, for example a breakdown of the source of income and/or gains, as this may help with the analysis and interpretation of AEOI data. It acknowledges that some respondents think that the request for further information to be supplied should be optional for taxpayers. This is an idea which may be explored in further detail at a future point.

2.25. Further consideration of changing the tax year is not being taken forward. This was explored in the 2021 Office of Tax Simplification report, The UK Tax Year End Date: Exploring the potential for change. The paper concluded ‘The costs of change are significant, both in terms of the financial cost and the opportunity cost. Whether moving to 31 March or 31 December, the work involved would consume government and private sector resources and make it much harder to implement other changes at the same time’. HMRC will consider other ideas which might help to reconcile international data with UK tax years.

Guidance and education

2.26. The discussion document asked for views on how HMRC can provide high quality help and accessible guidance for all taxpayers.

2.27. One particular point mentioned was that the terminology used in connection with international tax matters can be confusing for taxpayers. For example, sometimes the words ‘offshore’ or ‘foreign’ are used in ways which may be interchangeable or may mean different things depending on the context. Furthermore, some taxpayers have difficulty relating to these terms and may think that HMRC communications regarding offshore are targeted purely at wealthy taxpayers with complex arrangements and only those who pay income tax through self-assessment. A specific question was asked about this:

Question 6: What terminology do you think would help a broader range of taxpayers associate themselves more accurately with their offshore tax obligations?

2.28. While there were few written responses on this specific question, there was debate in the workshops. Most agreed that taxpayers with simpler tax affairs may not associate themselves with the term ‘offshore’ or consider that they fall into this category. Alternative terminology considered was:

• overseas
• international
• non-UK

Government response

2.29. It was agreed in the workshops that the most accurate description would be to raise awareness of having to declare ‘non-UK income and assets’. However, it was recognised that offshore has become the phrase used in legislation and guidance etc. and so this would be difficult to change. Therefore, more awareness, through communications on what is meant by ‘offshore’ may be more effective than trying to change the word used in existing legislation. However, using more neutral language in communications and education is being considered.

Public communications

2.30. The discussion document then explained that public communications can have a positive impact and mentioned several possible approaches.

2.31. The discussion document asked for views on how to improve public communications to raise awareness about offshore tax:

Question 7: In which areas of offshore tax should HMRC focus communication efforts and why?

Question 8: How should HMRC best carry out public communications to have the most impact in helping taxpayers get their offshore tax right?

2.32. Some respondents noted that awareness needed to be raised of relevant taxpayers’ obligations to declare Excess Reportable Income (ERI). They believed there was a general lack of awareness of this requirement amongst investors which can lead to non-compliance. This is made more likely as ERI should be declared even where the taxpayer has not received any payment in respect of it.

2.33. Respondents also indicated that improvements to the guidance on the taxation consequences of complex overseas structures would be helpful. Some thought that the transfer of assets abroad legislation needed to be made simpler and more accessible.

2.34. Some respondents agreed that creating a one stop shop on gov.uk for guidance on non-UK income and gains would be helpful for both taxpayers and agents and said that the guidance is currently hard to navigate.

2.35. The majority of respondents thought HMRC could do more to raise awareness through its social media platforms to inform taxpayers of potential UK tax obligations on non-UK income.

2.36. Other respondents suggested using townhall events to raise awareness of UK tax obligations in respect of non-UK income and gains.

Government response

2.37. In response to these suggestions, the Government is currently exploring a gov.uk ‘one stop shop’. At present gov.uk has a dedicated landing page aimed at those living or working abroad and offshore and another page aimed at businesses, International Tax: detailed information, which signposts users to relevant guidance. We are exploring how these can be refined for those with non-UK income and/or gains and recognise the need to further develop and tailor these pages to best support those customers.

2.38. The government recognises the need to make terminology more accessible and relatable to everyone and will review terminology used in order to achieve this.

2.39. The government acknowledges the point raised relating to ERI. There is a requirement in the offshore fund tax rules for fund managers to provide a report to participants for each reporting period. The report must include information on the amount of excess income treated as additional distributions per unit for each reporting period. The government will speak to industry to identify where there might be failures to provide adequate information to investors, and whether official guidance in Self-Assessment return notes and guidance manuals is adequate, to help ensure taxpayers have the information they need to correctly complete their tax returns.

2.40. The government notes the comments on improvements to HMRC guidance and the need to keep guidance under review.

2.41. The government announced on Tax Administration and Maintenance Day in November 2021 a new stakeholder forum, which will allow dialogue with stakeholders, such as those who responded to the discussion document, to continue. The ‘Offshore Forum’ will bring many benefits, including a continuation of the positive engagement which followed the publication of the two discussion documents. This Forum will enable HMRC to discuss with external stakeholders, at an early stage, policy and operational issues including guidance affecting HMRC’s approach to the taxation of non-UK income, gains and assets. This Forum will facilitate increased collaboration with stakeholders and the opportunity to comment on guidance

2.42. The government is currently in the process of developing a communications programme to raise customer awareness of tax obligations. HMRC has developed communication campaigns relating to foreign income and foreign rental income. This includes social media campaigns launched in November 2021 on Facebook, LinkedIn and Twitter, as well as a YouTube tutorial and a Webinar. These campaigns are designed, to assist customers meet their UK tax obligations concerning foreign income and gains, particularly those who are not represented. These approaches have been discussed at the Offshore Forum where members received the products positively. Members will also have the opportunity to suggest possible topics for the next round of guidance and education. These will continue throughout the year to help ensure taxpayers and their agents are aware of their UK tax obligations.

2.43. The government acknowledges the suggestion of townhall events, and other public meetings, to promote awareness of UK obligations and at present is considering the most effective ways to reach a wider audience. HMRC is engaging with members of the Offshore Forum to understand if there is industry appetite for this approach.

Informing taxpayers based offshore of their UK tax obligations

2.44. The discussion document recognised the communication challenges where taxpayers are based overseas and asked for stakeholder views on how HMRC can best communicate information about existing rules and the introduction of new rules to UK taxpayers based abroad, for example in the case of companies and individuals based overseas who may want to come to the UK for trade or investment purposes.

Question 9: How can HMRC raise awareness of changes in legislation when the target audience is based offshore?

2.45. The majority of respondents recommended a multi-channel approach and highlighted the difficulties offshore residents face in knowing the full extent of their UK tax liabilities and how to access guidance from the outset.

2.46. Respondents highlighted the need to raise awareness through agents and other intermediaries (the professional advisory community, including lawyers, trust companies, bankers and wealth managers, and representative bodies), in order to reach taxpayers based overseas. Some respondents mentioned that a large proportion of taxpayers do not seek professional advice as they are not aware that they require this and therefore, are not aware of their UK tax obligations.

2.47. Respondents suggested changes in legislation should be highlighted in advance in overseas publications for professionals, such as newspapers, both hard copy and online. Respondents suggested direct communications with offshore taxpayers. This can be achieved via prompts, but they cautioned against a ‘blanket approach’ and highlighted the need for follow up communications.

2.48. Respondents suggested public information campaigns should be considered in areas where there is a significant number of people likely to be required to pay UK taxes.

Government response

2.49. The government acknowledges the challenges in informing taxpayers based overseas of any changes in legislation. HMRC will continue to examine taking a multi-channel approach and is considering the variety of suggestions mentioned. HMRC has commissioned work to understand the customer population overseas with UK tax obligations so communication campaigns can be better targeted.

2.50. The government acknowledges the importance of providing sufficient time for taxpayers and agents to respond to any changes in legislation.

Digital prompts for taxpayers

2.51. The discussion document suggests HMRC could help taxpayers to get their offshore tax right first time is by making more use of ‘prompts’. A prompt in this context is any way in which HMRC contacts a taxpayer to suggest they consider whether tax may be due because of certain income or assets they hold or receive. This could be via a letter through the post, via a message appearing on screen while completing a self-assessment return, or any other method.

2.52. Digital prompts could better help taxpayers get their offshore tax right first time. HMRC has successfully trialled prompts in areas such as the VAT return.

Question 10: What data would be useful to you when receiving a prompt and when in the process would you like to receive it?

2.53. Respondents were keen for HMRC to share all the data we hold with taxpayers after the end of the UK tax year, where possible.

2.54. Respondent expressed the view that whilst prompts could be useful, if they are generic rather than personalised prompts, they may be of little use.

Government response

2.55. The government acknowledges suggestions that more data should be shared with taxpayers and is currently exploring this.

2.56. The government acknowledges that personalised prompts would be more useful than generic ones. HMRC has been running a 2 year pilot since December 2020 using offshore data received under the CRS and FATCA. HMRC is in the process of evaluating the impact of using prompts on the online tax return foreign pages to understand how they can be rolled out more widely.

2.57. The government is also considering a data sharing pilot, as mentioned above.

Working with agents and intermediaries to ensure offshore tax compliance

2.58. Intermediaries play a vital role in a healthy tax system. In the discussion document, the term ‘intermediary’ had a broad meaning, referring to any persons or entities that play a role between HMRC and the taxpayer concerning tax obligations. For example, agents, employers, financial institutions, and online platforms are intermediaries when helping taxpayers complete their returns, operating PAYE, or supplying data needed to complete returns.

2.59. The majority of tax advisers are competent, adhere to high professional standards, and are an important source of support for taxpayers. However, both Lord Morse’s independent review of the loan charge and the government’s call for evidence on raising standards in the tax advice market have shown that there is a minority of incompetent, unprofessional or malicious advisers whose activities harm their clients, reduce tax compliance, and undermine the functioning of the tax advice market.

2.60. We know that the majority of taxpayers trust the advice they receive from agents. This means that intermediaries are well placed to support taxpayers and help ensure they pay the right amount of offshore tax at the right time. HMRC works collaboratively with professional bodies to understand the role they play in supervising and supporting their members and raising standards in the profession and the majority of agents provide good quality advice. However, there are some agents who do not provide a good service.

2.61. This discussion document asked for views on how HMRC can help agents understand the tax affairs of their clients and predict client needs. It also asked about ensuring agents based outside the UK provide good quality advice.

2.62. To understand how HMRC could work better with intermediaries the following three questions were posed:

Question 11: How could HMRC work with agents and intermediaries to improve offshore tax compliance?

Question 12: What are your views about more direct sharing of information with agents?

Question 13: How can HMRC ensure agents based outside of the UK meet the standards expected of those giving UK tax advice?

2.63. The majority of respondents highlighted the importance of increased engagement between HMRC and intermediaries in order to improve of compliance and, suggested HMRC could work with intermediaries to; increase awareness in a specific location or sector, work with professional publications to write technical articles or help present webinars.

2.64. Some respondents mentioned that it is difficult to find an agent competent to provide professional advice on international tax and proposed that a database should be provided where agents can be searchable by location. This would help individuals to determine whether their agent is qualified.

2.65. A number of respondents agreed that sharing data directly with agents would allow for a more accurate and efficient process as it would help reconcile any discrepancies. Data sharing would also streamline the disclosure process and provide clarity to agents about the customer’s tax position.

2.66. Respondents took the view that HMRC would face difficulties in ensuring that agents based outside of the UK meet the standards expected of those giving UK tax advice and felt HMRC should not adopt a regulatory role. Instead the responsibility should be on the taxpayer to appoint a competent professional tax adviser.

2.67. Another suggestion was that HMRC could work with tax authorities in other jurisdictions to challenge agents that are not meeting acceptable standards, seek agreements to collect penalties imposed on agents and that HMRC could drive good behaviour by promoting accredited agents in communications. One point raised was that overseas tax advisors should be able to access HMRC guidance. It was also suggested that HMRC use overseas intermediaries to improve communications and raise awareness.

Government response

2.68. The Government recognises the importance of engagement between HMRC and intermediaries and acknowledges suggestions to further improve communication. In particular, we are keen to explore the use of toolkits (collections of useful advice), providing guidance in professional publications and creating webinars.

2.69. The Government recently published a summary of responses to the consultation document Raising standards in the tax advice market: professional indemnity insurance and defining tax advice. That document outlines the wider work taking place in HMRC on tax advice, it also details the commitments made by HMRC:

• to continue to explore options to improve the wider regulatory framework that supports standards in tax advice in consultation with stakeholders and in a way that fulfils the three criteria of clarity, transparency and enforcement. We have committed to publishing this consultation in 2022 including a potential legislative definition of tax advice

• in 2022, HMRC will update and publicise the HMRC Standard for Agents, and publish the conclusions of an internal review of HMRC’s existing powers to uphold agent standards

• to address concerns raised by customers and stakeholders in relation to repayment of tax refunds, the government also intends to consult next year on ways to tackle the sometimes high costs to taxpayers of claiming tax refunds using an agent

2.70. The UK already takes a leading role in the work on international tax issues which takes place within the Organization for Economic Cooperation and Development (OECD). The UK is a member of a number of the working groups where work is taking place to improve cooperation between jurisdictions. Guidance published on gov.uk is available globally. In addition, the UK provides help and advice to other countries which aims to improve their collection of tax.

Working with financial institutions to ensure offshore tax compliance

2.71. The document explored how to promote offshore tax compliance through HMRC working with financial institutions and the development of Public-Private Partnerships (PPPs) following the success of the Joint Money Laundering Intelligence Task Force (JMLIT).

Question 14: How could we further leverage public-private partnership initiatives and the role of financial institutions to promote offshore compliance?

Question 15: Are there other non-financial areas where public-private partnerships could be developed to help promote offshore compliance?

2.72. Some respondents took the view that financial institutions’ current professional obligations to their clients should suffice.

2.73. Other respondents wanted HMRC to work with financial institutions and other intermediaries, to improve offshore tax compliance. It was suggested that HMRC should consider holding workshops or seminars with financial institutions to promote the awareness of offshore tax compliance for their clients, with a focus on key expatriate communities as well as key jurisdictions for offshore non-compliance.

2.74. Respondents highlighted the existing relationships between professional bodies such as the Institute of Charted Accountants in England and Wales and HMRC. These give HMRC an accessible way to communicate across an industry of tax advisors in one go and gather views from the profession. Continued communication would support and enhance public-private initiatives.

2.75. Respondents suggested that HMRC could work more closely with overseas networks, professional bodies and the wider financial sector to promote the message about offshore tax compliance. It was also suggested that HMRC should continue to scope out opportunities to provide guidance and education to overseas taxpayers. For example, networks such as the Society for Trust and Estate Practitioners (STEP) Asia and the British Chamber of Commerce are wide reaching in Asia.

Government response

2.76. The Government is working with members of professional bodies through the Offshore Forum and are using this to communicate and work with the tax advisor industry.

2.77. In line with the No Safe Havens 2019 strategy the Government is continuing to explore how the UK can continue to lead internationally and increase use of its international network of Fiscal Crime Liaison Officers (FCLO) network to provide support for those based overseas. It also notes the suggestions and opportunities to link with other Government agencies and the private sector to educate as well as challenge risk in other jurisdictions.

3. Next steps

Action taken already

3.1. HMRC has created an Offshore Forum which allows the valuable dialogue with agents and other intermediaries, which started as part of this discussion, to continue.

3.2. The Offshore Forum allows HMRC to discuss developing policy ideas, and other ways of promoting tax compliance, with stakeholders. The first meeting of the Forum took place in November 2021, and meetings take place on a quarterly basis. If you would like further information on the forum please email nosafehavensForum@hmrc.gov.uk.

3.3. HMRC continues to deliver communication and educational products to taxpayers and their agents and has published YouTube videos, webinars and social media campaigns to help taxpayers get their tax right.

3.4. HMRC continues to play a leading role in international tax work, at the OECD, for example in the Forum on Tax Administration. HMRC also continues to work with other jurisdictions to help improve the collection of tax worldwide.

Future Action

3.5. Helping Taxpayers get Offshore Tax Right was published in tandem with Preventing and Collecting International Tax Debt, another discussion document. The engagement with customers and advisors which followed publication was combined and the two summaries of responses are being published at the same time. The process of developing and assessing the ideas received in the responses is already well under way but work will continue for some time.

3.6. When considering ideas two factors that will need to be considered are whether they support HMRC’s offshore compliance strategy, No safe Havens 2019, and the direction set out in HMRC’s 10 year strategy Building a trusted, modern tax administration system. Where appropriate, ideas will be subject to formal consultation.

3.7. It is important to note that this paper summarises the responses and is not a verbatim record of all responses due to the number and amount of detail provided. This paper does however, present the main ideas and arguments made in the responses.

Annex: List of stakeholders consulted

• AMP Tax Dispute Resolution
• BDO
• Blick Rothenberg
• BNY Mellon
• BSA
• Chartered Institute of Taxation
• CSM Tax Co
• Deloitte
• ECCU
• Ernst & Young
• Expat Tax
• Field Court Tax Chambers
• Field Tax
• Group Tax
• Hansuke Consulting
• Harbottle
• Institute of Chartered Accountants of Scotland
• Institute of Chartered Accountants of England and Wales
• Information Commissioners Office
• Low Income Tax Reform Group
• Kleinwort Hambros
• KPMG
• The Law Society
• McKenna Tax Consultancy
• MD Advisory
• Nat West
• OTS
• Pearl Lily & Co
• PKF Littlejohn
• PricewaterhouseCoopers LLP
• Ruffer LLP
• STEP
• SVB
• UK Finance
• UK USA Tax
• Utmost Wealth Solutions
• Zast Accountancy