IFAs to report on offshore structures
Written by Charlie Palmer on 10/08/2018

Offshore HMRC notification requirements are being enforced for IFAs.

In short, you must send the client this letter below if you provide financial advice or services to a client about overseas income or assets.

The best guide is here FCA notes-on-how-and-when-to-send-the-client-notification-letter

 The covering letter must read with the following text unchanged…

“The Set text:”

“From 2016, HM Revenue & Customs (HMRC) is getting an unprecedented amount of information about people’s overseas accounts, structures, trusts, and investments from more than 100 jurisdictions worldwide, thanks to agreements to increase global tax transparency. This gives HMRC unprecedented levels of information to check that, as in most cases, the right tax has been paid. If you have already declared all of your past and present income or gains to HMRC, including from overseas, you do not need to worry. But if you are in any doubt, HMRC recommends that you read the factsheet attached to help you decide now what to do next.”

Use this exact text, don’t make any changes. Apart from the set text, you can decide what else to include in the covering letter. You must send the letter before August 2017. The penalty for failure is £3k.

You don’t send it to clients who are NON UK resident during 2015-2017.

And of course, no need to do anything until next year…with deadline of august.

Given that all you are doing is acting as postman for HMRC, sending the text and letter attached, I can see that it will actually generate business if you do send it to all clients who you have advised to do offshore investments, because they will most likely ask you about it.

need more advice?

charlie.palmer@ifac.eu

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