Those originally making disclosures
- The most common scenario was UK resident (and domiciled) with undeclared assets in Switzerland, and commonly a Liechtenstein or Panamanian Foundation.
- Those who have "’inherited” ‘ a problem.
- Those who want their tax affairs resolved to ensure future generations do not inherit a problem.
Those who might otherwise be prosecuted: second offenders (have been through a previous enquiry/investigation but who did not disclose all overseas assets) and professionals (eg lawyers, accountants, barristers) or high profile people.
Those who have unrecorded trading income, diverted offshore, going back many years.
Those who wish to be able to use their offshore funds openly.
- Those who are genuinely worried about the existence of the overseas asset and want their tax affairs to be in order.
These people include those with assets held in Jersey, Guernsey and the Isle of Man.
Those who are now making disclosures
- Under the UK / Swiss Agreement, those whose deduction for the past hasn’t cleared all previous liabilities.
- Under the UK / Swiss Agreement, those who authorised disclosure and whose affairs still require regularisation.
- Those contacted by HMRC on unrelated campaigns, such as offshore property letters.
- Those with assets in the Crown Dependencies or Overseas Territories and who are aware of the impending tax information exchange with the UK.
- Those whose assets in Switzerland were moved in 2011 and 2012 and know about wider international pressures, moving towards automatic tax information exchange.