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It is clear the stakes have just been raised by HMRC in tackling offshore non-compliance. It is important that Requirement to Correct (RTC) is not seen as the domain of deliberate defaulters only. Anyone with offshore aspects to their UK tax affairs including non-residents liable to UK tax (e.g. offshore trustees and directors) should make use of the window available to review their position to determine whether a correction is required given the unprecedented sanctions that this legislation has introduced.
RTC will be in point for any tax found to be due in the future (i.e. after 30 September 2018) for the relevant years (even where due to tax technical issues) through HMRC enquiries, Common Reporting Standard (CRS) exchange or otherwise discovered. No one needs to fall foul of the 100 - 200% penalties. RTC encourages sensible and precautionary risk assessment measures to be undertaken now.
We can assist with: