You may be aware of the theft of data containing details of UK holders of HSBC accounts in Switzerland.
Now, HMRC have started acting on this, and are issuing Code of Practice 9 (Suspected Serious Fraud) letters to account-holders. The taxpayer is then unable to use the Liechtenstein Disclosure Facility (LDF) to regularise their tax affairs. COP 9 investigations are very different to local office enquiries.
This would explain why HMRC are taking this wholesale approach, regardless of the amounts involved.
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