Guidance on requirement to correct

HMRC has published guidance on complying with the requirement-to-correct rules. This condition is included in F(No 2)A 2017 s 67 and Sch 18 and obliges taxpayers to notify the tax authority if money held offshore has not been taxed or reported. It applies only to tax non-compliance before 6 April 2017 and taxpayers must notify any outstanding liability to HMRC by 30 September 2018.

The deadline coincides with the start date for the common reporting standard when the tax authorities in more than 100 countries will begin exchanging data on financial accounts.

Failure to disclose the relevant information to HMRC on or before 30 September 2018 will result in the person becoming liable to a new penalty as a result of their failure to correct. This is likely to be much higher than the penalties now with a minimum of 100% of the tax involved.

The tax non-compliance involves...