If you have not yet sent client notification letters to relevant clients, these should be sent by 31 August.
The International Tax Compliance (Client Notification) Regulations 2016 (SI 2016/899) amend the previous 2015 regulations and require certain financial institutions and professional advisers to contact their UK tax resident clients who have overseas income and assets. HMRC has said in its guidance that financial institutions and advisers falling under the obligations should:
notify them [clients] about information HMRC will receive under automatic exchange of financial information agreements with more than 100 jurisdictions
remind them [clients] of their tax obligations
highlight how they [clients] can make a disclosure
warn them [clients] about the increasing penalties and possible criminal prosecution if they fail to declare offshore assets.
The obligation is placed on financial institutions and also individuals and companies who provide advice or services to individuals relating to offshore accounts, income or assets. They are referred to within the legislation and guidance as a Specified Financial Institution and a Specified Relevant Person.
Tax advisers are clearly referenced within the guidance material. The ‘specified’ firms and individuals are required to identify those clients falling within the legislation and send notifications in the form prescribed by the regulations to them on or before 31 August 2017.