Overall, this legislation imposes obligations on certain advisers who provide “offshore advice or services” to specific clients, to send these clients an individually addressed covering letter from the adviser's firm/business. This letter must include certain wording provided by HMRC and must be sent by 31 August 2017. The covering letter from the adviser must also enclose a HMRC branded letter.

This correspondence is intended to alert clients to the possibility of HMRC compliance intervention in the event of untaxed income/gains derived from offshore activity. The letter also provides the client with guidance on what action they may wish to take by directing them to the Worldwide Disclosure Facility guidance on GOV.UK.

Chartered Accountants Ireland was involved in the informal 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.

This briefing note looks at key aspects of the Regulations as they may apply to members in practice only and does not examine the implications for Financial Services and Financial Institutions.