Consider now if your practice and client base are affected by the requirement.

Under the Regulations, advisers are required to use either the “general approach” or the “specific approach” to identify individuals to whom the prescribed notifications described must be sent.

• The general approach identifies individuals who were provided with advice or services relating to their personal tax affairs by the adviser in the relevant period.

This approach confirms therefore that HMRC have no objection to notifications being sent out to every client in the firm’s database if identifying specific individuals is too time-consuming or onerous.

• The specific approach identifies individuals who, in that period, were provided with offshore advice or services relating to such tax matters or were referred by the adviser to a connected person outside the United Kingdom for the provision of such advice or services.

Both approaches exclude individuals the adviser reasonably believes were not (or will not be) resident in the United Kingdom in either or both of the tax years 2015–16 and 2016–17 or for whom, on 30 September 2016, the adviser has no reasonable expectation of advising further or providing more services.

The specific approach similarly excludes individuals for whom the adviser has prepared and delivered (or expects to do so) a personal tax return disclosing the effect of the advice or services provided.

An individual identified using the general approach may be similarly excluded if the adviser so chooses.