Would it be better if HMRC focused its efforts elsewhere?
HMRC’s latest enforcement campaign focuses on direct sellers – those selling products door-to-door or through home ‘parties’ – with the hope that individuals will simply own up using the amnesty and send in their disclosure with a cheque attached.
The carrot is that those who come forward to put things right face a penalty of up to 20% rather than the 40-100% that HMRC can charge if it discovers tax irregularities. The stick is that if direct sellers do not make voluntary disclosures HMRC will use its powers under FA 2008 Sch 36 to obtain information from businesses known to use direct sellers so it can target specific individuals for follow-up investigations. However from the first offshore disclosure facility onwards there has only...