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.



Pension transfer advice – assessing transfer risk
Alistair MacDougall Compliance 2015, 2018, 2019, 2021, DBAAT, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
It has been well publicised that the FCA has aimed increasingly close scrutiny in the direction of firms that have been providing advice in relation to defined benefit pension transfers. Apparently caught off guard by the then Chancellor’s introduction in the Pension Schemes Act 2015 of what are generally called ‘pension freedoms’, the regulator has […]