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HMRC sends ‘nudge’ letters on offshore investment funds

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HMRC is sending letters to certain taxpayers dealt with by its wealthy and mid-sized business unit during November, reminding them to check that they have correctly reported income and gains from offshore collective investment funds.

The CIOT has been provided with a sample of the letter and factsheet taxpayers will receive, explaining the two types of offshore investment funds, ‘reporting’ and ‘non-reporting’, and the taxation treatment of each (see

  • For reporting funds, all distributions received or deemed to have been received during the tax year are taxable. CGT will be due on gains or losses on a disposal of the fund. Income deemed to have been received includes excess reportable income, which is interest or dividends received by the fund, but not distributed.
  • For non-reporting funds, income tax is due on distributions actually received in the year. Gains on disposals are taxed as income under the offshore income gains rules, which means no use can be made of the CGT annual exemption or taper relief.

According to Steven Porter, a partner at Pinsent Masons, HMRC has made 540 requests to overseas authorities for information on UK taxpayers in the past year. This is a 24% increase over the number of requests in the previous year.

HMRC laid out its approach to hidden offshore assets in an updated ‘no safe havens’ strategy paper in March, indicating the use of criminal investigations to send a strong deterrent message to taxpayers.

‘HMRC recently admitted it was behind on opening investigations into hidden offshore assets. This could kickstart more investigatory activity, so taxpayers must be prepared for a renewed push’, Steven Porter said.

HMRC’s specialist ‘offshore, corporate and wealthy’ unit has recovered over £1bn from investigations in just three years and generated £560m in 2018/19 alone.

Issue: 1464
Categories: News