Legitimate planning has been undertaken for decades to establish offshore structures to protect wealth, whilst minimising any exposure to tax.
The real question is whether or not the planning undertaken in the 1970’s and 1980’s has stood the test of time?
In the 2000’s, there is the additional task of demonstrating that an offshore structures have economic substance.
For most offshore administrators, hopefully this will be no more than another unpaid administrative chore to be undertaken by the relevant offshore provider.
But then there is perhaps always the “odd one out” that has never been fully understood.
Reports under the Common Reporting Standard
A report may have already been made under the Common Reporting Standard – but that report may have been incorrect or misleading.
Previous administrators of the structure may have never “got to grips” with the day to day reality and possibly the author/creator is no longer available. Maybe there is historical baggage that comes with it – and at a cost!
No matter how often you meet with the family, perhaps the original UK business has diversified and the family itself has moved on. No one can fully recall all the rationale of what was done or whether the structure resembles the original business idea.
Can the structure still be justified?
Is it effectively no more than a brass name plate? Is now the time to reach a Settlement with HMRC?
Or should an alternative tack be taken? Perhaps under the circumstances, should HMRC’s questions be put on hold?
We all have our professional reputations to retain and maintain so why would you want to risk anything for just the one rogue structure.
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