HMRC will start to receive information from overseas jurisdictions concerning UK resident individuals who receive income from or hold financial assets overseas. Those who choose not to disclose such income and assets will potentially be subject to the harsher penalty and assessment regime being introduced from September 2018.
Agents have until 31 August 2017 to write to their clients including specified paragraphs and attaching HMRC’s information sheet.
Whilst there are three approaches to take concerning who you choose to write to, at this point the safest route is to write to all of your clients to ensure that you catch all of those who may have undisclosed offshore income or assets. Failing that, you can either identify and write to clients to whom you either provided offshore advice or services, or referred overseas for this, OR identify and write to all clients you’ve provided with (any) advice or services in respect of their personal tax affairs between 1 October 2015 and 30 September 2016
If your clients come forward wanting to make a disclosure, this may still be done within the worldwide disclosure facility but time is of the essence, and whilst the penalties relating to such a disclosure will still be substantial, they will still be significantly less than the potential 200% penalty which can be levied under the new regime.
Those agents who fail to write to their clients could be liable to a one-off penalty of £3,000.
If you require any advice or assistance concerning a potential disclosure, please contact the Croner Taxwise consultancy team on 0844 728 0120 or email email@example.com.