HMRC increasingly shows two different faces to the world – one that invites consultation, co-operation and collaborative engagement, and the other that promises severe penalties and criminal sanctions against persistent and deliberate evaders. So, this year, the litigation strategy was ‘refreshed’ which in practice meant finding a path to settlement in entrenched cases became a little easier, although still not as straightforward as many would like, and at the same time a far more co-ordinated approach to offshore evasion emerged, with the UK/Swiss treaty at its heart.
