Guidance

Guide to sending the client notification letter

Updated 16 January 2017

Overview

If you’re classed as a ‘Specified Financial Institution’ or ‘Specified Relevant Person’ you may need to send the notification letter to clients who are UK tax resident if you’ve:

  • provided them with financial advice or services
  • provided them with an overseas account
  • referred them for an overseas account
  • referred them for advice or services overseas

You must send the notification letter to all relevant clients between 30 September 2016 and 31 August 2017.

If you’re a charity, you don’t need to send the notification letter to clients.

Meaning of Specified Financial Institution

A Specified Financial Institution could be a:

  • bank
  • building society
  • insurer
  • fund manager
  • wealth manager
  • investment entity or similar business

Meaning of Specified Relevant Person

You could be classed as a Specified Relevant Person if you’re a:

  • tax agent or adviser
  • solicitor
  • financial adviser

Clients you need to notify

You only need to send the notification letter to clients who are a UK tax resident in either the:

  • 2015 to 2016 tax year
  • 2016 to 2017 tax year

If you’re classed as a Specified Financial Institution

To find the clients you need to notify, you can choose between the:

You only need to use one of these approaches. If you don’t find any clients to notify from an approach, you don’t need to do anything else.

If you’re classed as a Specified Relevant Person

To find the clients you need to notify, you can choose between the:

  • specific approach - identify individual clients you’ve provided with offshore advice or services, or referred overseas for this
  • general approach - identify all clients you’ve provided with advice or services for their personal tax affairs (between 1 October 2015 to 30 September 2016)

You only need to use one of these approaches. If you don’t find any clients to notify from an approach, you don’t need to do anything else.

If you’ve referred a client for offshore advice or services

You still need to send the notification letter to clients if you’ve referred them for:

  • an overseas account
  • advice or services overseas

You must notify the client even if you didn’t offer advice, products or services directly.

How to send the notification letter

You must send a covering letter to your client along with the notification letter (PDF, 31KB).

You can send these to your client by:

  • post - if you’re a Specified Relevant Person or Specified Financial Institution
  • email - if you’re a Specified Relevant Person and this is way you usually communicate with your client and you reasonably believe they will read it

If you’re sending the notification to your client by email, you can class the email itself as the covering letter, as long as you include the right information.

The covering letter must include:

  • your usual branding
  • your client’s name and address on
  • set text

If you’re a financial institution the set text must say:

“Financial institutions in more than 100 jurisdictions around the world are being legally required to find out the tax residence of their account holders and report details of their accounts, structures, trusts, and investments to be exchanged with the appropriate tax authorities. As a UK tax resident, any overseas accounts you have will be sent to HM Revenue & Customs (HMRC). This gives HMRC unprecedented levels of information to check that, as in most cases, the right tax has been paid.


If you have already declared all of your past and present income or gains to HMRC, including from overseas, you do not need to worry. But if you are in any doubt, HMRC recommends that you read the factsheet attached to help you decide now what to do next.”

If you’re a relevant person the set text must say:

“From 2016, HM Revenue & Customs (HMRC) is getting an unprecedented amount of information about people’s overseas accounts, structures, trusts, and investments from more than 100 jurisdictions worldwide, thanks to agreements to increase global tax transparency. This gives HMRC unprecedented levels of information to check that, as in most cases, the right tax has been paid.


If you have already declared all of your past and present income or gains to HMRC, including from overseas, you do not need to worry. But if you are in any doubt, HMRC recommends that you read the factsheet attached to help you decide now what to do next.”

Use this exact text, don’t make any changes.

Apart from the set text, you can decide what else to include in the covering letter.

When to send the letter

You must send the notification letter to any qualifying clients between 30 September 2016 and 31 August 2017.

If you don’t send the notification letter

If you don’t identify and send the notification letter to clients who need it, you could be charged a one-off penalty of £3,000.