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CIOT guidance on requirement to correct

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The CIOT and ATT have issued a note for their members giving practical guidance for advising clients on the requirement to correct offshore tax non-compliance by 30 September.

The note is arranged under broad headings which cover:

  • what has to be corrected;
  • professional advice that can be relied upon to provide a reasonable excuse and ‘disqualified advice’;
  • asset-based penalties and what constitutes ‘awareness’ of non-compliance; and
  • interaction with disguised remuneration loan charge settlement terms.

See Practical notes for CIOT and ATT members (at