Earlier this year, we provided you with an update on the legislation and guidance supporting the client notification requirement contained in section 50 of the Finance (No. 2) Act 2015. Section 50 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.

This Institute was 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.

HMRC have recently contacted us to advise that the Regulations have been laid and are due to come into force on 30 September. HMRC will be issuing full guidance in due course and this Institute will be developing a briefing note to assist members.