HSBC Jersey: whistle blower names account holders. HMRC has been given a list containing the names of over 4,388 HSBC bank account holders who are living in the UK by a whistle blower from HSBC’s Jersey office.

According to the Daily Telegraph the list “identifies 4,388 people holding £699 million in offshore current accounts and they are also likely to have billions of pounds more in investment schemes. Several celebrities and other well-known figures are understood to be identified in the client data.” 

As Jersey is a Crown dependency and an offshore financial center and specializes in trust and fiduciary services many billions are held Jersey accounts in the name of trustees and offshore companies. HMRC’s haul seems unlikely to include the names of trustees based in Jersey (many of whom are going to be Jersey Trustee companies in any case). However it presumably depends on how the list is compiled to see who the whistle blower has included. Many non-domiciled individuals in the UK will have established offshore trusts and so need not be overly concerned about the disclosure if they are using the remittance basis. 

Conversely, the list may be of deep concern to any non-domiciled individuals who are living in the UK who are named as account holders and do not pay the remittance basis charge. 

HMRC will start comparing the details with its own records and tax return details and will in course contact any account holders.

On 12 November 2012 HMRC launched a new campaign warning "tax cheats" to come forward and disclose their income. This is part of a Government £917 million scheme to tackle tax evasion, avoidance and fraud from 2011/12, which aims to raise an additional £7 billion each year by 2014/15.

The Liechtenstein Disclosure Facility remains the most favourable regime for those with undeclared Jersey or foreign income. 

Since 6 April 2011 increased tax-geared penalties apply in relation to errors and failures relating to offshore income and capital gains.

Please contact the Virtual Tax Partner support line for assistance in making a disclosure.