Key points
- It is now more than six months since overseas entities need to disclose details of their registrable beneficial owners.
- HMRC is using data received under automatic exchanges of information including the Common Reporting Standard and numerous other datasets including land registry data.
- Changes in registrable beneficial owners and beneficiaries of interested trusts between 28 February 2022 and 31 January 2023 will soon be disclosable.
- Undisclosed income can be reported using HMRC’s new disclosure facility or the contractual disclosure facility.
More than six months have passed since the deadline for overseas entities to disclose details of their registrable beneficial owners and information about relevant trusts to Companies House on the register of overseas entities (ROE). See my article ‘HMRC: an evolving approach to offshore tax’ Taxation 7 February 2023 for an explanation of how the ROE fits with HMRC’s compliance approach.
HMRC has now...