Offshore tax investigations

What they ask about an offshore account

Where did the money come from, and was it taxed in the UK? Has UK-taxable income or gains arisen on the account (interest, dividends, disposals)? If they think the answer is fraud, they may go criminal or open COP9. If they think it is avoidance, COP8. If the data is incomplete they may open an ordinary enquiry first.

Accounts in the name of an offshore company are in scope where the beneficial owner is UK resident. We first establish residence and domicile (and, for current years, the residence-based rules for foreign income and gains). Then we test whether HMRC is entitled to the documents they have demanded. Extra cooperation can be given voluntarily — but HMRC should be told that it is voluntary.

How Solaratax helps

If the account was used to keep untaxed UK income or gains, we manage the enquiry or a voluntary disclosure, including the Worldwide Disclosure Facility where that is the right door.

Call 01615 314179 or email enquiries@solaratax.co.uk for a free, confidential discussion. We will not contact HMRC in your name until you instruct us to act.

Questions we are asked

Related investigations

• Worldwide Disclosure Facility

  A structured way to tell HMRC about offshore interests — it does not buy immunity from a criminal investigation.

• Residence and domicile enquiries

  Whether you are UK tax resident, and how historic domicile claims still matter for earlier years.

• Code of Practice 9 and the Contractual Disclosure Facility

  Serious suspected fraud: admit and disclose under CDF, or deny — with a 60-day outline disclosure if you accept the CDF.

• HMRC voluntary tax disclosure

  Telling HMRC before they tell you. Unprompted disclosure is how penalties fall and how criminal risk is reduced.