I hope everyone in the UK enjoyed their Summer because Autumn has definitely arrived… a cold wind blows in and with that comes a raft of new measures and updates from HMRC. Common Reporting Standard data is starting to arrive at HMRC HQ and below I highlight the punitive sanctions that HMRC has at their disposal for taxpayers who fail to ensure that their tax affairs are not entirely compliant prior to the 30th September 2018 Requirement to Correct deadline.

Below I have also listed some developments in September which I hope might be of interest.

New members of the Edwin Coe Tax team

The Tax team continues to go from strength-to-strength and we remain extremely grateful to our loyal clients and partners who continue to refer their friends and contacts to us. As a consequence of the increased demand, this month we welcomed two new senior members to the tax team, Mala Kapacee and Bill Duggan.

Mala and Bill both have a wealth of experience and I am delighted that we have been able to add people of this calibre to our team.

Requirement to Correct – the clock is ticking

Less than 1 year remains for all taxpayers who have or have had any offshore financial connections to ensure that all their tax returns are correct. This includes checks to ensure implementation of planning and technical opinions (for example that those who claim to be non-UK domiciled can correctly do so) are in order. Anyone who has or has had an interest in an offshore structure or claimed the remittance basis needs to have their tax affairs sense-checked.

The deadline to correct is 30 September 2018 – so less than a year away.

Failure to correct could result in:

  • penalties of between 100% and 200% of the tax not corrected
  • potentially an asset based penalty of up to 10% of the value of the relevant asset (where tax at stake exceeds £25,000 in any year)
  • potential that the taxpayer will be ‘named and shamed’ where value of correction exceeds £25,000 in total
  • a potential further penalty of 50% of the standard penalty if HMRC can demonstrate that the assets or funds have or had been moved in an attempt to avoid the Requirement to Correct regime.

Please contact either Sean Bannister or myself  to discuss how we can work with you to review either your own tax affairs or those of your clients. The deadline for correction is looming and failure to do so allows for some extremely severe financial consequences. The Tax team has a wealth of experience available to review and if necessary, correct, any offshore arrangements which are or have been held.

Facilitation of Tax Evasion

From 30 September 2017 new measures went live which will target corporations who fail to prevent tax evasion.

See below a link for further information:


HMRC’s Executive Chair is to retire

Edward Troop will retire from the role at the end of 2017:


New Anti-Avoidance rules for offshore trusts

The new measures are scheduled to go live from 6 April 2018 onwards:


HMRC – Senior staff travel report

Ever wanted to know where HMRC’s senior staff have been travelling to… and which class of travel they have used? See below:


Autumn Budget date announced

The Autumn Budget will be delivered on 22 November 2017.

Other news

The Online Trust Register deadline is delayed.

The Institute of Chartered Accountants in England and Wales has reported HMRC’s announcement to extend the deadline for registration from 5 October to 5 December 2017.

Non-Domicile figures for 2014/15

For those who may not have already seen this, the first ever non-dom figures have been released which show that during 2014/15 there were 85,400 RNDs in the UK of which 54,600 were claiming taxation on the remittance basis. RNDs paid a total of £8.7 billion in UK income tax and NIC and £250m in CGT.

Thank you to all loyal readers of the Bite Sized Blog – please do contact me directly if there are any matters we can assist you or your contacts with, or if you require any further clarification on the various topics raised above.

Have a great October.

Kind regards

Frank Strachan
Partner | Head of Tax
For Edwin Coe LLP
d: +44 (0)20 7691 4136 | e: frank.strachan@edwincoe.com

Edwin Coe LLP is a Limited Liability Partnership, registered in England & Wales (No.OC326366). The Firm is authorised and regulated by the Solicitors Regulation Authority. A list of members of the LLP is available for inspection at our registered office address: 2 Stone Buildings, Lincoln’s Inn, London, WC2A 3TH. “Partner” denotes a member of the LLP or an employee or consultant with the equivalent standing. This guide concerns the law in England and Wales and is intended for general guidance purposes only. It is essential to take specific legal advice before taking any action.

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