HMRC have apparently agreed with the German tax authorities that where an offence is thought to have been committed by a UK citizen, the German authorities will make the necessary requests of the Swiss. In the UK, only quite exceptional tax offences are criminal offences, so there is no question (at this stage) that the agreement will be used as justification of a ‘fishing exercise’ for the hidden cash of tax evaders.
HMRC claim to be targeting only the hidden funds of organised criminals and fraudsters as well as those whose tax evasion amounts to fraud. However, it is said that there are ‘tens of thousands’ of British subjects with Swiss bank accounts. If this latest probe by HMRC yields significant results, the Government may be expected to put pressure on the Swiss government to allow HMRC direct access to details of British nationals and residents who hold of Swiss accounts.
HMRC are increasingly using the criminal law when dealing with cases involving large-scale tax evasion. If a successful prosecution is obtained, they can then apply for confiscation orders to seize the ‘criminal assets’ of the offender. It is probably only a matter of time before the first prosecutions are brought of people who have squirreled away ill-gotten gains in Switzerland.