Requirement to Correct - Practical Notes for CIOT and ATT Members updated

We have produced these practical notes for use by members following recent discussions with HMRC regarding the scope and operation of the “Requirement to Correct Offshore Tax Non-Compliance” (RTC) in Schedule 18 Finance (No 2) Act 2017. 

Part 5 of the notes has been updated to reflect that HMRC’s RTC guidance does not cover the Disguised Remuneration Settlement Terms so it does not explain what will happen where a taxpayer has not finished the correction process on a DR settlement by 30 September 2018.