Important – requirement to notify clients with overseas assets or income

Do you have any clients with income or assets overseas?

If you do, then you need to be aware that HMRC now require you to notify your clients about HMRC requirements in relation to any overseas income or assets. Full details can be found here.  

This notification requirement applies to –

Specified Financial Institutions
Generally, this includes banks, building societies, insurers, fund managers, wealth managers, investment entities or similar businesses.

Specified Relevant Persons
Generally, this includes tax agents / advisers, solicitors and financial advisers.
Note that a Relevant Person is the business, and can be an individual, a company, a partnership, or similar entity.

Which clients need to be notified?
Any client who is a UK tax resident in either the –

  • 2015 to 2016 tax year
  • 2016 to 2017 tax year

And that you have advised or referred in respect of their offshore:

  • self-employment income
  • employment income
  • savings
  • investments
  • profit from selling assets abroad

When sending the standard letter, you must include a covering letter containing set text. Both the text and the letter are available from the link given earlier.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

For information and action as appropriate.

Action Required By You

  • Read the full Guide on the HMRC website at the link given earlier;
  • Note that firms failing to comply with this requirement could face a financial penalty of £3,000;
  • Make sure you’ve identified all clients who need the letter by 31 December 2016;
  • You must send the notification letter to any qualifying clients between 30 September 2016 and 31 August 2017.
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About the Author

Technical Manager - Often referred to as the Oracle or the Sage, Alistair has a wealth of financial services experience. He is our go-to Technical Manager and enjoys nothing more than a complicated conundrum. Feel free to test his renowned knowledge by getting in touch.

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