The client notification requirements were introduced by Finance (No 2) Act 2015 section 50 and came into force on 30 September 2016. They impose an obligation on tax advisers and other persons to send a HMRC branded communication to their clients about the Common Reporting Standard, the penalties for offshore tax evasion and the opportunities to disclose offshore evasion to HMRC via the new Worldwide Disclosure Facility.
These have the potential to affect all members in practice. If you are affected by these measures you will need to provide the notification to certain individuals who were clients as at 30 September 2016, before the notification deadline of 31 August 2017.
On this page you will find information about these obligations, and practical tips on how to comply.
CIOT Webinar and Q&As
A recording of the CIOT’s webinar held on 1 December 2016, plus slides and Q&As, can be found here.
Tax Adviser Magazine
In the December 2016 issue of Tax Adviser magazine, Richard Wild, Head of the CIOT’s Technical Team, explained why advisers may have to send HMRC-branded correspondence to their clients, and how this might be achieved. The article can be found here.
Legislation and HMRC guidance
- Worldwide Disclosure Facility landing page.
- Client notification landing page.
- Guidance for recipients of the client notification.
- Guide to sending the client notification letter.
- Full guidance on the client notification in the HMRC manual.
- The regulations in full.
Further details and links can be found here.
CIOT submission on the draft legislation introducing this measure
On 7 October 2015 we submitted our response to the draft clause in Finance Bill 2015 (clause 46). Our submission can be found here.