A duo of tax investigators, Andrew Watt and Rebecca Busfield, have left Alvarez & Marshal Taxand UK and set up a new investigations consultancy, Watt Busfield Tax Investigations LLP (WBTI).

The firm has been set up to provide confidential advice to individuals, partnerships or companies on how to use voluntary disclosure opportunities provided by HMRC or will assist those entities, which have already been challenged by HMRC, to make a full disclosure.

Andrew Watt, partner at WBTI, says: 'As HMRC continues its relentless pursuit of untaxed funds in various havens around the globe, it is highly likely that, over the next few years, the UK will seek to replicate the Swiss agreement with other jurisdictions.'

Last year's agreement between authorities in the UK and Switzerland will ensure that untaxed funds held in Swiss banks by UK resident individuals will be regularised, albeit on an anonymous basis. However, there is no guarantee that those who suffer this tax will be immune from investigation at some time in the future, warns Watt. The Swiss government will in due course provide HMRC with the names of the top 10 destinations to which funds have been transferred in anticipation of the tax.

The only full amnesty for UK taxpayers with untaxed funds held offshore is the Liechtenstein Disclosure Facility (LDF), which will remain in place for another four years.

Andrew Watt, QDR, MAE served for a number of years in the Inland Revenue including six years as a fraud investigator in Enquiry Branch (now HMRC Specialist Investigations). He subsequently headed the tax investigations function in a number of leading consultancies. He is also co-chairman of the Tax Investigations Practitioners Group.