TaxSource Total

Here you can access relevant source documents which support the summaries of key tax developments in Ireland, the UK and internationally

Source documents include:

  • Chartered Accountants Ireland’s representations and submissions
  • published documents by the Irish Revenue, UK HMRC, EU Commission and OECD
  • other government documents

The source documents are displayed per year, per month, by jurisdiction and by title

What must be done and by when?

A notification letter must be sent by the Specified Relevant Person to the client to whom they provided the affected advice. The Regulations also note that it may be appropriate to translate the notification.

The letter must be sent by 31 August 2017 and must contain both:

  1. a specific document under HMRC branding providing information and links to the relevant HMRC guidance; AND
  2. a covering letter from the business of the Specified Relevant Person sending the notification (this must contain specific wording).

Links to both of the above are provided below.

The notification letter therefore highlights that there are opportunities for clients to voluntarily disclose information about their overseas tax affairs, if they need to, by providing a link to HMRC’s guidance on the Worldwide Disclosure Facility. However the HMRC insert does not highlight that the disclosure opportunity available under the Worldwide Disclosure Facility essentially only lasts until 30 September 2018.

HMRC are calling the Worldwide Disclosure Facility “the final chance to come forward” before HMRC begin to use Common Reporting Standard data. A tougher approach to offshore non-compliance will also begin after 30 September 2018 when new sanctions under the Requirement to Correct legislation will be introduced. A disclosure is still possible after 30 September 2018 but on less favourable terms.