It is consulting on even tougher penalties for those who evade tax through offshore structures, ahead of the introduction of the fresh data-sharing arrangements with authorities in the Crown Dependencies and British Overseas Territories (CDs and BOTs). Automatic exchange of information on financial accounts held by UK taxpayers in the CDs and BOTs will initiate in October, single year priorto a wider Common Reporting Standard (CRS) will initiate to introduce the same arrangements at a global level.

HMRC will also introduce a fresh Worldwide Disclosure Facility (WDF) from 5 September 2016. The WDF will not offer any special terms, as was the case with HMRC’s previous disclosure facilities; but will grant those with outstanding tax to pay to locate their affairs in order.

The plans are portion of HMRC’s desire to get “tougher on tax evasion”, according to Jennie Granger, director general of enforcement and compliance at the authority.

“We will discover those who reflect they can dodge paying tax in this nation,” she said.

“We’ve closed aged disclosure facilities, increased penalties and ramped up our powers to tackle evaders and those that assist others evade – the days of any safe havens for tax evaders are numbered. Our message is simple -–come to us and pay the tax and penalties that are due, priorto we target you with the introduction of even tougher sanctions and game-changing data,” she said.

The consultation sets out a fresh requirement for those that possess not yet paid UK tax due on historical offshore interests to do so by September 2018, priorto the fresh automatic exchange of information agreements come into full effect the following month. Those that do not meet the requirements by this date would be subject to a fresh set of legal sanctions for “failing to correct”.

HMRC has locate forward two potential penalty models for consultation: a simple approach, with a minimum penalty of 100% and maximum penalty of 200% of the unpaid tax; or a variable approach, in which penalties would be charged at three levels depending on the circumstances, amount owed and whether the disclosure was ‘prompted’ or ‘unprompted’. Penalties would be levied in entire cases unless the taxpayer could demonstrate a “reasonable excuse” for not meeting their obligations, and would be reduced depending on the extent to which the taxpayer cooperates with HMRC.

In its consultation, which closes on 19 October, HMRC acknowledged that both proposed penalty models were “set at a high level compared with the standard penalties as they stand at the moment”. However, it noted that those subject to the fresh penalties would possess “committed an original offence, they will possess failed to come forward beneath any previous disclosure facility and will now also possess failed to correct beneath the fresh legal obligation”.

“This is a significant failure on the taxpayer’s portion and we feel it should therefore attract increased rates of penalty compared with the standard penalties for offshore evasion,” HMRC said.

The fresh penalty regime will operate in addition to previously-announced measures affecting “entire those involved in offshore tax evasion”, according to HMRC. These include a fresh ‘strict liability’ criminal offence of failing to declare offshore earnings and gains, increased civil sanctions for offshore tax evaders and fresh civil sanctions for ‘enablers’ of offshore evasion.

“We possess seen a number of disclosure facilities come and depart, but the recent raft of consultation documents build it clear that HMRC is genuinely clamping down on those who evade taxes,” said tax expert Fiona Fernie of Pinsent Masons, the law firm behind

“This really is the endure chance saloon – once HMRC receives information beneath UK FATCA and CRS it will no longer crave to rely on taxpayers to come forward. Those who possess not taken advantage of the WDF or the RTC will possess no excuses, and will be sanctioned accordingly,” she said.