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HMRC internal manual

International Exchange of Information Manual

Notification requirement: Specified Relevant Persons: Legal firms and other non-tax advisory businesses

Specified Relevant Person is broad enough to include businesses that predominantly offer legal advice, but also offer tax advice.  It will also include predominantly tax advisory businesses that have sub-divisions that provide purely legal or other non-financial advice or services.

The general approach identifies specified clients as those to whom the business has offered advice or services relating to the clients own tax affairs.  Where the Specified Relevant Person chooses the general approach, it may choose to exempt any clients, groups of clients, or business divisions where it reasonably believes that they will not have provided any advice relating to the personal tax affairs of those clients in the year to 30 September 2016 due to the nature of that part of the business.

This is intended to allow firms who are principally legal advisers to exempt most of their client base, and only send to those dealt with by their tax specialists.  Similarly, where a tax advisory firm has a team or department that deals wholly with legal or other non-tax advice, they may exclude that client base.