It may be too late for 7,000 Australian holders of accounts with the tax haven branches of Australian based banks to make voluntary disclosures of their as yet untaxed offshore tax haven interest income.
Writing in the Australian newspaper today Susannah Moran reports that as part of the Australian Tax Office’s (ATO) ongoing Project Wickenby tax evasion investigations, Australian banks have handed over “…information on a large number of people with bank accounts in offshore jurisdictions”.
The banks conceded this information following a decision of the Full Federal Court in the case of Australia and New Zealand Banking Group Limided v Konza  FCAFC 127 where it was held that a Section 264 information notice issued to the bank in connection with accounts held at their Vanuatu branch was valid.
Assistant Deputy Commissioner Michael O’Neill also indicated the ATO have already matched over 7,000 customers. Many of these have, or will be receiving “please explain” letters or more extended audit activity. Those taxpayers are likely to have missed the opportunity to make voluntary disclosures that would otherwise limit the extent of penalties for tax evasion.
Those taxpayers who are large-scale evaders might also face criminal charges.