Developments in communication and transparency reveal a new disclosure facility.

The Isle of Man Government has recently released details of a Memorandum of Understanding between them and HMRC whereby a disclosure facility has been made available to UK residents and legal persons (such as companies, trusts and foundations) with undisclosed funds held offshore.

Features of the IoMDF: The disclosure facility became available from 06 April 2013 and runs until 30 September 2016. Any individuals or legal persons have the opportunity to disclose all amounts held offshore from 06 April

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1999, in respect of individuals, and 01 April 1999, in respect of legal persons. The benefits of using the facility are reduced penalties, starting at 10% of the tax due, and a bespoke service when dealing with HMRC. It is also an ideal opportunity for UK individuals or legal persons to regularise their tax affairs with HMRC.

HMRC have drawn up the bespoke service to deal with any initial enquiries on a “no names” basis. Thereafter users of the service will have a single point of contact within a discrete HMRC team in order to ensure consistency of treatment. The facility also offers the potential to pay back any funds by instalments (subject to certain conditions) and a guarantee that the individuals (or legal persons) making the disclosure will not be named or shamed.

There are, however, certain individuals and legal persons who cannot take advantage of the disclosure facility. These are: anyone who is under investigation as at 06 April 2013, anyone currently using the Liechtenstein disclosure facility, anyone who qualifies as a relevant person under the Swiss/UK Tax Cooperation Agreement. Individuals who have previously been the subject of investigations, which have subsequently closed, can still take advantage of the disclosure facility for any amounts not disclosed to HMRC under the previous investigation - albeit without the opportunity to have reduced penalties.

Alongside the Isle of Man, fellow crown dependencies Jersey and Guernsey have also signed a Memorandum of Understanding on the same terms as the IoMDF.