HMRC has been both criticised and praised for its efforts in tackling both tax evasion and abusive tax avoidance, perhaps dependent on who or what is has been the subject of HMRC investigation. The new penalty regime has had the greatest impact and, together with HMRC's changing methodology of carrying out investigations by way of interventions and disclosure facilities plus more successful and better publicised prosecutions, is bringing about a radical change in our tax compliance culture. Does the new Swiss/UK tax treaty run counter to this progress, bearing in mind the increasing level of mutual co-operation internationally to counter tax evasion?
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