Client notification (offshore income and assets)

Is this only for undelcared aspects?

Didn't find your answer?

I am havign a disagreement with a colleague about the notification requirements and am getting a little concerned now due to the 31st August deadline.

If clients have offshore income and assets that have been declared to HMRC via tax return, etc, do they still need to be notified?

Colleague believes that it only applies to those clients who have / may have foreign income / assets which have never been delcared but this is not my interpretation.

I suppose there is also the argument to say that any client 'may have' offshore assets that we don;'t know about so everybody should be notified.

On the other hand, if it is only undeclared income / assets that the agent knew about, then surely the agent should have acted on this a long time ago without the need for HMRC to impose this.

I am obviously missing something here but cannot see what and, though I am likely wrong, I do not believe my colleague has fully grasped this either.

Any advice would be greatly appreciated.

Replies (3)

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By Tax Dragon
10th Aug 2017 12:59

I assume you are talking about SI2015/878 (the International Tax Compliance Regulations 2015)? It would help us to assist (I would not attempt to answer) if you could be specific.

Are you and your colleague disputing Reg 12C?

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By MBK
11th Aug 2017 13:55

In short - you have (as a minimum) to write to anyone who has declared overseas income or gains on a tax return in the last three years.

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By SteveHa
11th Aug 2017 16:08

Or whom you have advised regarding overseas income. For safety, I'm doing a SATR reminder session and tagging it on to all of the reminders.

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