Q&A: How is HMRC going to trace the holders of £50m of unallocated certificates of tax deposit?

In response to a recent freedom of information request by RSM UK HMRC confirmed it still holds almost £50m of unallocated monies under the now ceased certificate of tax deposit scheme. Here we consider the likelihood of HMRC tracing the remaining certificate holders and actions to be taken by those HMRC does contact.

What is the background to the scheme closure?

On 22 November 2017 the Treasury announced the long running certificate of tax deposit (CTD) scheme would be closed for new certificate purchases with effect from 23 November 2017. It advised it would continue to honour existing certificates until 23 November 2023 and that holders should contact the dedicated CTD team before that date to allocate the certificates against specific tax liabilities. Alternatively holders could choose to submit requests to encash the certificates and withdraw the amounts deposited before or promptly after this deadline. However...