In 2023/24, information requests between HMRC and foreign tax authorities concerning UK taxpayers have reached their highest level in at least seven years, according to data obtained by Price Bailey.
The data, released under the Freedom of Information Act, reveals that 2,388 information requests were made or received by HMRC regarding taxpayers with assets in both the UK and overseas in 2023/24. HMRC made 632 outbound requests in 2023/24, fewer than the 777 made in 2022/23, but nearly double the number from the pre-pandemic period (331 in 2018/19).
According to Price Bailey, the volume of information exchanged is expected to rise this year following the Spring Budget announcement that non-UK assets will be subject to inheritance tax, capital gains tax, and income tax based on residence rather than domicile starting 6 April 2025.
In 2023/24, HMRC issued 23,500 nudge letters related to offshore matters, a slight decrease from the 23,936 issued in 2022/23. However, the monetary value of disclosures resulting from these letters nearly tripled from £19.6 million in 2022/23 to £57.2 million in 2023/24.
Andrew Park, Partner at Price Bailey, stated, “We have been seeing increased HMRC scrutiny of wealthy individuals with overseas assets. This is likely to intensify following the abolition of the non-dom tax regime, which will bring more offshore assets within the UK tax net. HMRC will rely heavily on requests to foreign tax authorities to build a picture of the increased tax liabilities of wealthy UK residents. It is likely that some UK residents who currently take advantage of non-dom status will fail to disclose their full liabilities to HMRC.”
Park added, “HMRC began issuing nudge letters in 2023/24 to wealthy individuals named in the Pandora Papers. It cannot be a coincidence that the amount generated from offshore nudge letters nearly tripled to almost £60 million as these taxpayers came under HMRC’s spotlight.”
