The requirement to correct rule

The Finance (No. 2) Act 2017 contains provisions requiring disclosure of historic non-compliance to HMRC by 30 September 2018: the "requirement to correct" rule.  This is part of a range of legislation targeting offshore tax evasion.  

HMRC expects the data exchange that will shortly take place as a consequence of the Common Reporting Standard (CRS), and other information exchange programs, will provide them with details they need to establish non-compliance. 

Defences for failing to comply with the requirement to correct are limited and it may not be sufficient to have relied on legal or tax advice.  Prompt action is required now to potentially avoid very significant penalties.  

In this article, Anthony Thompson and Robert Payne discuss the scope of the rule and what action should be taken now as a consequence.

The requirement to correct rule - The Finance No2 Act.pdf