Provided that a relevant person agrees either to make a one-off payment in accordance with Article 9 of this Agreement or to make a voluntary disclosure in relation to his/her relevant assets in accordance with Article 10 of this Agreement and fully cooperates with HMRC, that person is highly unlikely to be subject to a criminal investigation by HMRC for a tax-related offence for past liabilities in respect of relevant assets from the date he or she irrevocably opted for one of the options, unless either his/her relevant assets represent the proceeds of crime (other than crime connected to a tax-related offence) or represent the proceeds of crime connected to criminal tax-related offences punishable by two years or more imprisonment.
Right, that’s from HMRC. Cough up your tax evasion and we’ll not prosecute. Except, of course, if it’s all based on criminal enterprise or offences in the first place.
So, at the same time as it was being decided it was worthwhile pursuing very large numbers of people for benefits related issues, including non-payment, through the UK court system it was decided that it was not a good use of that system to pursue wealthy people and their professional advisers for proven, deliberate, large scale criminal acts of theft.
And that’s Ritchie. But theft is a criminal act for which you would be prosecuted. Therefore they’re not not prosecuting people for the criminal act of theft. They’ve actually laid out that they would prosecute for that.
Now Ritchie may want to say that not paying your taxes is an act of theft. But the law doesn’t agree. Which is why HMRC is making the distinction, see?