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HMRC internal manual

MLR1 Penalties Guidance

From
HM Revenue & Customs
Updated
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Penalties guidance: TCSPs/ASPs/EABs identifying relevant clients

A relevant client is someone that the business provided regulated services or products to during the relevant period. A relevant client can be an individual, business, partnership, trust or any other body. For example, the vendor and purchaser clients of an EAB.

If a client had an ongoing business relationship with the business, but did not receive regulated services from the business within the relevant period, they were not a relevant client. If specific clients are to be excluded, businesses must be able to show us that no work for which either an invoice would normally be issued, or accrued fees recorded, was provided in the relevant period.

In addition to the regular clients with whom there is a business relationship, it will also be necessary to identify if the business provided any services in the relevant period on an occasional basis outside of a business relationship. The onus is again on the business to disclose these details to us.

Relevant clients will always be clients who were active in the relevant period. Dormant clients in the relevant period who are simply maintained on businesses books are not relevant clients.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)