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Register of overseas entities – latest developments

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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 received the non-public trust information from Companies House and we’ve been working hard to integrate this with information about registrable beneficial owners to identify possible tax non-compliance.

This information provides HMRC with unparalleled insight into the true beneficial ownership of UK property which can be very valuable for assessing tax risks and by cross-referencing against the information we already hold we’ve identified thousands of UK resident beneficial owners.

We know that many of these arrangements were set up many years ago...

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