HMRC have contacted us to advise that they have now developed and published their GOV.UK pages and websites on the client notification requirement. As previously covered in Chartered Accountants Tax News, The International Tax Compliance (Client Notification) Regulations were released and came into force on 30 September 2016.

The regulations amend the International Tax Compliance Regulations 2015 by requiring financial institutions and certain advisors to identify individuals to whom notifications, as outlined in the regulations, must be sent on or before 31 August 2017 (along with a covering letter from the financial institution/advisor using set wording provided by HMRC and the relevant links to guidance).

This legislation imposes obligations on advisers providing “offshore advice” to clients, to send an individually addressed covering letter from the adviser’s firm which must include certain wording provided by HMRC; the letter must also enclose a HMRC branded letter. The correspondence is intended to alert clients to the possibility of HMRC compliance intervention in the event of untaxed moneys being held abroad.

The notification letter directs readers who need to bring their tax affairs up-to-date to the Worldwide Disclosure Facility page. This has been updated to include a link to the guidance for recipients of the notification. The guidance explains why clients have received the notification and what, if any, action they should take.

The client notification landing page which went live in October now includes a guidance summary “Guide to sending the client notification letter” for financial institutions and advisors. This includes links which direct users to HMRC’s more detailed guidance in the International Exchange of Information Manual.

Below is a summary of the relevant links for the client notification requirement:

• Worldwide Disclosure Facility landing page: https://www.gov.uk/guidance/worldwide-disclosure-facility-make-a-disclosure
• Client notification landing page: https://www.gov.uk/government/publications/client-notification-income-or-assets-abroad
• Guidance for recipients of the client notification: https://www.gov.uk/guidance/income-or-assets-abroad-letter-about-your-uk-tax-affairs
• Guide to sending the client notification letter: https://www.gov.uk/government/publications/client-notification-income-or-assets-abroad/notes-on-how-and-when-to-send-the-client-notification-letter
• Full guidance on the client notification in the HMRC manual: https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim600000
• The regulations in full: http://www.legislation.gov.uk/uksi/2016/899/contents/made

Chartered Accountants Tax News notified readers of the coming into force of the regulations. This Institute was also involved in the consultation process which followed the introduction of the legislation. The Institute’s aim was to minimise the pressure on members in practice from this obligation, where possible. A briefing note to assist members is currently being developed and will be available in the next few weeks.