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ML reporting for client with late tax returns

Do I need to make a report for a client behind on their tax returns?

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Hello

I have a personal tax client who has not provided the information for their tax returns for several years now (going back 5 tax years!). It is likely that there will be tax payable for each year, but HMRC have not yet made determinations for the outstanding years (I suspect this will happen soon).

Despite numerous requests, the information is not forthcoming. I also act for a company that they are director/shareholder of, which is less behind, but still not up to date.

I am getting to the point at which I am considering disengaging. As part of this though, I also need to consider whether I need to make a Money Laundering report. Does the client's failure to meet their self-assessment reporting requirements equate to them benefitting from the proceeds of crime? My instinct is that it does, but I would be grateful for any guidance from fellow professionals.

I post anonymously for (hopefully) obvious reasons.

Thank you.

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Hallerud at Easter
By DJKL
25th Feb 2020 11:15

Why are they so behind needs answered to consider whether reporting is needed?

If reporting is required why only now when proposing disengagement?

How on earth did you allow them to get that far behind in the first place, frankly I would have stopped acting for the client years ago?

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RLI
By lionofludesch
25th Feb 2020 12:35

I'm guessing HMRC are probably aware of this already.

I wouldn't be submitting an SAR on the basis of what you say.

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By carnmores
26th Feb 2020 19:19

I agree they know what the situation is , the problem this highlights is that they dont make best use of the information they already have

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By legerman
26th Feb 2020 19:54

Quote:

I'm guessing HMRC are probably aware of this already.

I wouldn't be submitting an SAR on the basis of what you say.

Neither would I, but this client would have been disengaged after the first year late. In fact I've done it twice before. One who had a Ltd Co but wouldn't supply any paperwork for me to do the next VAT return after engagement and wouldn't communicate with me at all. The other a sole trader who never gave me anything to do the SA tax return. Gave it a few months then disengaged.

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