Are you writing a novel or is this a real concern? No one would suggest it as an ideal situation but where it falls on the spectrum of naughtiness depends on many other factors.
Pretty much every "service" available from HMRC requires separate authority to access, some of which still seems to fall through the cracks in terms of actually speaking with them about it - VAT still seems to be a shambles in this area (if I'm not the agent and you cannot discuss the matter with me, why was I copied in on it?)
In direct answer to your question here, I think any remedy here is going to be with the company/prior accountants rather than HMRC however I think it raises more questions than answers particularly if the client sold the company for £200k in 2004 (eh, a lot of money in those days mind) but didn't receive it, what exactly did he do until 2015/16 when he got his pension?
You could conceivably be making this worse depending on that answer.
You are thinking about it too much. It's a meaningless sop by the powers that be to pretend they are taking such issues seriously.
Get the client to sign the declaration the rest of us are going to do and try not to get up thinking about your handyman client who doesn't pay for the correct permit at the tip.
I see from the latest article the upcoming wheeze is going to be charging clients for AML compliance. They didn't make clear how we do this if we decide not to proceed with the client because of said checks.
£20/40k fees is likely to be achievable with marketing/networking. I'd be concerned that such a small portfolio would be more likely to come from someone retiring ahead of MTD and possibly difficult to make profitable in the glorious new regime.
That is why I hedged with "arguably" but I would consider the phone call received from the client being the notice of termination of the relationship.
I suppose we get could get into the detail of what engagements letter terms state & what disengagement procedure was undertaken & possibly refer to the rules of whatever Institute we may belong to.
Even if the client toddles off to the local Cowboy who doesn't bother with the niceties of handover information or even having an Agent Account with HMRC, I wouldn't be confident that making an official report/record of the fact you accessed this thereafter wouldn't land you in bother with your Institute - there would be a relatively high chance they would review this given their particular interest in AML.
My answers
Are you writing a novel or is this a real concern? No one would suggest it as an ideal situation but where it falls on the spectrum of naughtiness depends on many other factors.
If the old boy did pay CGT on the £200k in 2004, he's been one hell of a good sport about the £115k he hasn't received.
Pretty much every "service" available from HMRC requires separate authority to access, some of which still seems to fall through the cracks in terms of actually speaking with them about it - VAT still seems to be a shambles in this area (if I'm not the agent and you cannot discuss the matter with me, why was I copied in on it?)
In direct answer to your question here, I think any remedy here is going to be with the company/prior accountants rather than HMRC however I think it raises more questions than answers particularly if the client sold the company for £200k in 2004 (eh, a lot of money in those days mind) but didn't receive it, what exactly did he do until 2015/16 when he got his pension?
You could conceivably be making this worse depending on that answer.
You are thinking about it too much. It's a meaningless sop by the powers that be to pretend they are taking such issues seriously.
Get the client to sign the declaration the rest of us are going to do and try not to get up thinking about your handyman client who doesn't pay for the correct permit at the tip.
I formed a company on Tuesday and had it through a couple of hours later. Possibly varies by region?
I see from the latest article the upcoming wheeze is going to be charging clients for AML compliance. They didn't make clear how we do this if we decide not to proceed with the client because of said checks.
You would have to admire that level of optimism.
£20/40k fees is likely to be achievable with marketing/networking. I'd be concerned that such a small portfolio would be more likely to come from someone retiring ahead of MTD and possibly difficult to make profitable in the glorious new regime.
That is why I hedged with "arguably" but I would consider the phone call received from the client being the notice of termination of the relationship.
I suppose we get could get into the detail of what engagements letter terms state & what disengagement procedure was undertaken & possibly refer to the rules of whatever Institute we may belong to.
Even if the client toddles off to the local Cowboy who doesn't bother with the niceties of handover information or even having an Agent Account with HMRC, I wouldn't be confident that making an official report/record of the fact you accessed this thereafter wouldn't land you in bother with your Institute - there would be a relatively high chance they would review this given their particular interest in AML.