Mr. Niall Cody:

We have no evidence that money flowed from HSBC Dublin into HSBC Private Bank (Suisse). If one looks at the coverage, some of the HSBC explanation and rationale is that the bank took over a Swiss private bank in the late 1990s and HSBC see it as a different type of entity with a different culture. I am not here to defend HSBC London but its view is that the bank took over a Swiss private bank and claims that the standards that obtained in Switzerland were not the standards the bank upholds.

From a tax administration point of view, what is really interesting is that the focus on the facilitation of bank secrecy, in terms of the story and the coverage of it, has helped improve transparency. The Swiss authorities have signed up for the OECD common reporting standard, CRS, which is the next generation of exchange information about bank secrecy. Were Revenue to appear before this committee ten years ago and were members to ask Frank Daly, as it was at the time, whether he expected the Swiss would sign up to exchange information about bank secrecy, he would have said this would be a really big challenge. We now are looking at that opportunity. This raises something about which my board colleagues and I must think, namely, when the Foreign Account Tax Compliance Act, FATCA, agreement dealing with exchange of information between the US Internal Revenue Service, IRS, and Revenue comes into place, followed by the CRS with effect from 2017, to which more than 90 countries have signed up for the automatic exchange of banking information. There are people who unquestionably have money offshore that involves tax evasion and that is an absolute fact. Consequently, we must consider how we can leverage international developments to ensure that we get our money. If there are people who opened bank accounts offshore since 2002, my advice to them is they should be making voluntary disclosures before we find out further about it.