At the beginning of July, HMRC substantially rewrote its guidance for its staff on information exchange in their International Manual to reflect their current approach to interactions with foreign jurisdictions given rapid changes to the global tax environment. When viewed in conjunction with a growing number of exchange of information agreements, increasing pressure on the international stage for countries to clean up their image as tax havens and HMRC’s current focus on aggressive or abusive tax avoidance schemes, the net is closing on offshore evasion and avoidance. While of specific interest to those with outstanding offshore issues to clear up, with the introduction of a new penalty regime for offshore matters, all taxpayers with current cross-border transactions or worldwide investments should note the growing importance of being able to demonstrate reasonable care in the event of any inaccuracies or future enquiries.