self eomployed new client already written to HMRC to switch to Remittance Basis (RB) an amend TR before seeking advise. I have looked at his TR and noted (obviously) they have not decalred any foreign income nor have they remitted any income to the UK. So there are only few options here .
option 1 - amend return under arising basis, tax will be higher as undeclared income will now be included and taxed in UK
option 2 - amend return under RB basis , as there is no income remitted to the UK , so this will makes tax higher as PA will be lost.
option 3 - do nothing - can be dangerous if an enquiry is opened or error is found.
option 4 - amend retrun and include Double taxation relief , no better than option 1.
No RBC applies and return is within 4 yrs time limit and income under 100K.
Any possible thoughts to make this idea more appealing, i have not done one of these for a long time. I will surely do some reseach this weekend , but just reaching out on a brainstoming exercise.