HMRC letters received by several Buzzacott clients in recent weeks about overseas income and gains have included a schedule of information with details of offshore data held by the tax authority, the firm has told Spear’s.
Justin Stevenson, a tax investigations specialist at Buzzacott, said it was the first time he had seen HMRC include specific offshore data in letters of this kind and information on where it had come from.
‘The schedule includes useful detail about the offshore data held by HMRC which led to the nudge letter being issued, including the name of the financial institution that provided the data, a description of the amount reported and the year it relates to,’ he said.
[See also: Do HMRC’s letters to billionaires spell the end of ‘complete privacy’?]
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In the past, HMRC has sent ‘nudge letters’ to taxpayers it suspects may not have fully declared their overseas income, assets or gains, Stevenson said, and invited them to disclose via its ‘Worldwide Disclosure Facility’ (WDF), which is for any tax liabilities connected to an offshore issue.
What was different about letters he had seen in the last two weeks, Stevenson added, was the inclusion of specific data, and the note: ‘Check you’ve told us about all your UK tax liabilities from all income or gains, not just those in the schedule at the end of this letter.’
‘It’s only been over the last couple of weeks, and I don’t know whether it’s going to be in every WDF message. It might just be the ones that we’ve seen, but we haven’t seen it in the past,’ Stevenson said.
Stevenson praised the letters as ‘a welcome step towards transparency from HMRC’, but said anyone who receives them risked ‘much harsher penalties’ should they decide not to respond.
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‘Each case is going to be different, but theoretically, if HMRC have sent somebody a nudge letter about an overseas source of income that isn’t included on their tax return, and then they don’t come forward, then HMRC can open an investigation,’ he said.
[See also: Budget 2026: How could it affect your wealth?]
In September, HMRC wrote to billionaires with a UK tax footprint, and invited recipients to (voluntarily) provide details of their trusts, assets and property. Some recipients, though not all, were also invited for meetings with HMRC.
Earlier this week, the Financial Times reported that plans to introduce a new visa route to the UK for wealthy people from overseas would not be included in John Healey’s Budget which he will deliver on 28 October.
The UK’s Tier 1 (Investor) visa, which offered a ‘fast track’ route to residency in the UK for applicants able to invest at least £2 million in the UK, was closed by the previous Conservative government in 2022.
HMRC did not immediately respond to comment.
