At one of the regular meetings we had with HMRC, there was a short presentation from the Offshore Evasion strategy team. They are keen to get the message out to taxpayers that automatic exchange of information in the shape of the Common Reporting Standard will be coming in relatively soon, with the first exchange of information between tax authorities due in 2017. At that point tax authorities will start to get a flood of very detailed information on anyone with financial assets overseas. They would much prefer that taxpayers in this situation take action now to regularise their affairs via the disclosure options that are available rather than see a whole raft of taxpayers being faced with enforcement action after tax information exchange has commenced.
Many practitioners are probably currently focussed on ensuring FATCA reporting goes smoothly and have not yet given too much thought to the arrival of the CRS, but the message from HMRC is a timely one and highlights the benefits of ensuring that clients are fully aware of the need to regularise their tax affairs if need be, ahead of the new international reporting arrangements coming into force.