Carnell attributes this shortfall to how poorly LDF was publicised.
The very advantageous terms, which include immunity from prosecution, will never be repeated again, he advised. Those with undeclared offshore assets, who fail to take advantage of LDF before the window closes, will face the full force of HMRC.
“All of these things were known, but were not communicated effectively enough, in my view, to accountants, solicitors, intermediaries, or to advisers,” Carnell told International Adviser.
Time running out
In future, information about financial accounts that is required to ensure tax is paid will be automatically transferred between the countries involved. Individuals with undeclared offshore assets are running out of places to hide, Carnell cautioned.
He continued: “The first exchanges will take place in 2017. Other countries, including Switzerland, plan to exchange information for the first time in 2018. Passive legal entities will be included, meaning private individuals standing behind foundations and trusts will be identified.
“Importantly, it will allow tax authorities to verify whether their taxpayers have correctly reported all their assets; ie including those held outside their territory in another AEOI state and whether these assets have been taxed.
“There are two months left for advisers to alert their clients to the LDF and the generous terms it offers as an amnesty before the opportunity disappears. Time is now very short,” Carnell warned.
