Research and analysis

Behavioural factors influencing use of offshore disclosure facilities

Research exploring behavioural factors influencing the use of HMRC's offshore disclosure facilities for those with undeclared offshore assets.


Behavioural Factors Influencing use of Offshore Disclosure Facilities

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email Please tell us what format you need. It will help us if you say what assistive technology you use.


This research explores behavioural factors influencing the use of HMRC’s offshore disclosure facilities for those with undeclared offshore assets. The aim was to better understand the motivations and drivers of offshore disclosure and how HMRC might be able to influence taxpayers to generate more disclosures. Forty in-depth interviews were conducted during August and September 2014, with tax agents who handled a reasonable volume of Liechtenstein Disclosure Facility disclosures. The agents were asked to discuss their experiences from across their client base.

The key findings of the research:

  • For the most part, the agent view was that clients who used offshore disclosure facilities did not see themselves as having done anything wrong and sensitivity is required to ensure these individuals self-identify as non-compliant
  • HMRC’s efforts need to be targeted not at ‘disclosure’, but at encouraging people to ‘review their affairs’, reminding them that they are responsible for ensuring they are compliant, and urging them to seek specialist advice. Agents can then recommend disclosure as the best way of sorting out a problem
  • Motivation to act depends both on accepting the likelihood of getting caught and the perceived severity of the consequences
  • Intentional evaders may continue to procrastinate where they believe that other facilities will come along and/or HMRC doesn’t have the resources to target evaders - even after international information exchange
  • Agents play a critical role in helping confirm non-compliance, and make risk real
Published 15 July 2015