STEP England & Wales Biannual Statement July 2017

Rita BhargavaIt is a pleasure to be writing to you for the first time as Chair of STEP’s England & Wales Regional Committee to let you know about the work we are doing on behalf of members in the region.

We’ve been performing well, with 93% of member renewals for 2017 received and 350 new members in the last six months. We’ve also seen more than 100 enrolments on STEP’s England and Wales Diploma in that time.

From a practice perspective, the recent political turmoil has impacted on our sector in various ways. Two issues of note were the draft legislation on the taxation of non-domiciliaries and offshore trusts and the probate fees debacle – both of which placed enormous strain on practitioners. STEP has been active on both fronts on behalf of members and their clients.

Finance Act 2017
The proposed changes to the UK’s taxation of non-domiciliary rules, which were due to come into force on 6 April 2017, were extremely complex and left a number of areas of uncertainty, which STEP’s UK Technical Committee highlighted to HMRC. The answers received were then collated in a Guidance Note for members’ information. However, the proposed changes were dropped from Finance Bill 2017 (now Finance Act 2017) to enable the bill to get through Parliament ahead of the General Election.

We’ve now heard that the proposed changes will resurface in a new Finance Bill after the Summer Recess, and will be backdated to 6 April 2017. This brings some welcome certainty, but it should not be forgotten that there are further changes on the horizon for non-doms and offshore trusts, which may be brought in later this year or next, so any planning will need to factor these in.

Probate fees
The proposed increase in probate fees announced earlier this year placed a huge strain on both probate registries and practitioners as everyone struggled to be ready for the May deadline. STEP was extremely active on this issue from the outset, expressing concern about the fairness, practicality and legality of the proposed increase, and obtaining a legal opinion from Richard Drabble QC, which stated that an increase in fees on the scale suggested could not be achieved without fresh legislation. You can read an overview of STEP’s activity here.

When the probate fee increase was put aside ahead of the General Election, we all breathed a sigh of relief. But we are not out of the woods yet: rumour has it that this may resurface, and we are keeping a close eye on the situation.

Public awareness
Politics aside, a lot has been happening at STEP in recent months.

It was great to see the launch in May of a new campaign to raise awareness of STEP and TEPs among UK consumers. A key part of this is the launch of www.advisingfamilies.org – a public-facing website providing information on issues relating to the services STEP members provide. It’s backed by a digital campaign – ‘You can talk to a TEP’ – to raise awareness and drive people to the website.

Many members and their firms have got involved, contributing content and engaging with the campaign on social media. If you haven’t yet had a look at the website, I’d recommend you do so. You can read more about the campaign and how to get involved here.

Speaker Register
Work has also been underway to develop a Speaker Register, which branches and central event organisers will be able to use to find speakers for their events. This exciting new development offers members the opportunity to put themselves forward for speaking opportunities. More than 300 members have already registered their interest in speaking via their Online Profile, so if you want to feature on this, make sure you register today.

So – a busy six months; with lots more to come, no doubt, as the year progresses. I look forward to reporting on that in December, but for now I hope you get at least a little respite over the summer to recharge for what’s ahead.

Rita Bhargava TEP
Chair, STEP England & Wales Regional Committee

Happy 25th birthday STEP Jersey!

George HodgsonI had the pleasure of attending STEP Jersey’s AGM and 25th anniversary celebration this week. STEP Jersey is one of our largest branches, with over 1200 members, and is also one of our most active. Not only does it host many well-attended events, but it works closely with government, regulators and others to ensure the jurisdiction maintains its position as a respected international financial centre.

Indeed it is fair to say that STEP Jersey plays an integral and important role in the economic life of the island, with the trust industry one of the largest local employers.

Much of the discussion focused on how to ensure that STEP, both locally and internationally, could maintain the success of its first quarter century well into the next. In conversations over a most enjoyable traditional cream tea (with the welcome, but less traditional, addition of a glass of Prosecco) I was struck by the confident tone of many senior professionals who were present.

They fully acknowledge the challenges that increased transparency and a consequent explosion in compliance costs will bring. Rather as with Brexit in the UK, however, the mood was generally ‘what is done is done – so let’s get on with it.’

I am delighted to see that STEP Jersey is setting up a policy-focused committee to ensure there are effective links with local regulators and others to work through the rapid changes now underway.

The team at STEP Worldwide will continue to give STEP Jersey (and other branches working on these issues) all the support we can in helping develop a coherent and well-informed strategic approach to the trust industry in the new age of transparency.

George Hodgson is Chief Executive of STEP

Embracing a new skills agenda

EPP forumThese days, the world seems to be changing faster than it spins on its axis. While the headlines darken each morning with geo-political and economic tumult, the sense of unease continues reading beyond the front pages. A bleak outlook for the workplace: robots will take over, professions will be rendered obsolete by new technology; a Fourth Industrial Revolution is less than a mouse-click away…

Participants in a global economy, we are available 24:7. How can we thrive in these modern times? Where do we find breathing space? How can organisations find time to develop its staff without taking them from business as usual activities? How can individuals cultivate a work-life balance or reflect on their place in the world?

Such questions were posed by the STEP Employer Partnership Programme’s inaugural Summer Forum last week in London. Hosted by BDO, the evening included high-profile speakers drawn from the trusts and estates industry and the learning and development world to explore these issues. Participants were given a powerful call to action to embrace a new skills agenda and innovate in their practice.

BDO’s Head of Private Client UK, Paul Ayres, opened the programme. Reflecting on the changing role of the tax practitioner, his observations will resonate with contemporaries in the tax world as those in other professional services:

How can your organisation meet changing client requirements? How do you promote yourself in a world that increasingly denigrates the value of professional advice as the internet perpetuates the fallacy that everyone can be an expert? How can you make an agile response to constantly changing governmental and regulatory constraints? How can you keep ahead of legislation, embrace technology, maintain global competitiveness and deliver your services at the right price point? How do you retain your trainees, who are entering the workforce now with very different expectations of work from their supervising partners? How do you give the same quality of training you experienced, when the advent of digitisation has rendered obsolete the opportunities to develop the practical and client-care skills embedded in the training contracts of old?

Leading learning and development specialists Liggy Webb, Jonathan Winter and Jane Hart gave impassioned responses as to how we interpret these challenges. We all wish to be more flexible and confident in the way we approach challenges in life, both at work and at home. Liggy Webb delivered strategies for resilience – emotional sunscreen to help us confront those challenges head on and keep us sane.

Jonathan Winter discussed how careers really work, blowing away the cobwebs on the traditional model of the career trajectory that most have entered the workplace with, debunking myths about how we think about work and leaving us with seven habits crucial to future-proof a career.

Jane Hart, closing the programme, addressed the changing world of work and urged delegates to embrace new technologies, adopt learning tools and strategies that embed a culture of learning within individual, team and organisational outputs. Drawing on examples of pioneering practice from players like Google, she deftly illustrated how this can be done without the onerous burden on budgets human resource training often presents. A lively Q&A offered a stimulating debate on these ideas.

By the close of the evening it was clear that those employers who adopt a proactive approach to change and empower their employees similarly will thrive. Those investing time, as well as financial and intellectual capital into their workforces will reap the land of plenty in the future. Embracing new models of learning and working, and viewing technology as an enabling force, not a threat, will help them withstand the social seismic shifts and lead the new skills agenda for the modern workplace.

Madeleine Jenness, STEP Education Manager

STEP Caribbean Conference, Cayman

George HodgsonI have just enjoyed a highly informative STEP Caribbean Conference in Cayman from May 1-3, which attracted well over 300 delegates from across the STEP world.

Presentations ranged from the emerging theme of cryptocurrencies, which I suspect is a wholly new topic to many in the audience, to the use of firewall provisions in fending off matrimonial claims.

What really stood out, however, is the changing mood across much of the Caribbean regarding transparency and the rising regulatory burden. Yes, these developments are providing major challenges, particularly in driving costs up sharply across the board.

This was a theme very clearly evidenced in STEP’s Offshore Perceptions research report last autumn. But the message from a string of eminent speakers is that the time is gone to complain about this; it’s time instead to ‘get on with it’ and ensure that businesses adapt to the new environment they are now working in.

This obviously echoes the mood in the UK regarding Brexit, where whatever the views of STEP members on the issue, I sense most agree that we need to now accept it is going to happen and plan on that basis. Indeed Brexit and its potential implications for the offshore world was another key issue which attracted a full house.

The Caribbean Conference, which is now in its 19th year, remains one of the flagship STEP events in the calendar and I look forward to next year’s meeting in Barbados.

 

George Hodgson is Chief Executive of STEP

Probate fees: how we got to where we are

Emily Deane TEPFollowing the news late last week that the UK government is scrapping its plans to hike probate fees, Emily Deane TEP looks back on an eventful 15 months for STEP and practitioners.

February 2016
In February 2016 the Ministry of Justice (MoJ) issued a consultation paper on reforms to the fee system for grants of probate. The paper proposed to increase the fees for estates of over GBP50,000, with a banded fee structure depending on the estate value. Larger estates faced a 13,000 per cent rise to GBP20,000.

STEP strongly opposed the new system on the basis that the proposed fee would be completely disproportionate to the service provided by the probate court, and would effectively be a new tax on bereaved families.

We raised concerns on the grounds of fairness, practicality and legality, in particular that the new measures being introduced via the Draft Non-Contentious Probate Fees Order 2017 may be ultra vires, i.e. beyond the power of the order.

The consultation was widely circulated, with over 97% of respondents opposing its proposals. Then the matter went quiet for almost a year.

February 2017
On 24 February 2017, STEP received notice from the MoJ that, subject to parliamentary approval, and despite overwhelming opposition to the proposals, the new fee system would be implemented in May 2017: just weeks away.

Concerned that this would have a huge impact on bereaved families and their legal advisors, we set out to highlight the issue to ministers, the media and the public.

We contacted the MoJ highlighting our concerns and requesting a meeting. We received no reply, with the MoJ remaining extremely quiet on the issue. No clear information was posted highlighting the new fee structure to the public, with a discreet link to the consultation response on the gov.uk website the only notice that these changes were coming.

We therefore sought to raise public awareness of the issue, issuing press releases and explaining our concerns to the media, and developing guidance for members of the public.

Our work paid off, with national media including BBC Moneybox, the Daily Mail  and the Mirror  covering the issue. Our guidance for the public was viewed nearly 2,600 times and our social media channels were buzzing with activity.

April 2017
Then at the beginning of April we heard that the influential House of Commons Joint Committee on Statutory Instruments had questioned the legality of the proposals, given that the new ‘fees’ looked very like taxes. But while hopes were raised, the government continued to push forward with no changes to its plans.

Concerned that the issue would not be given proper scrutiny, STEP obtained a legal opinion from leading expert in public law, Richard Drabble QC, who agreed with the SI Committee’s findings and confirmed that ‘the proposed Order would be outside the powers of the enabling Act’.

Then, on Tuesday 18 April, Prime Minister Theresa May called a snap election. The pressure was suddenly on to get all orders through before parliament was dissolved.

On Wednesday 19 April the House of Commons Second Delegated Legislation Committee rushed though the Non-Contentious Probate Fees Order 2017 meeting at 8.55am, with no advance warning that it would be tabled that day. It was approved 10 to 2.

On Thursday 20 April we finally received a response from the MoJ to our earlier letter, dismissing our concerns and advising that the fee changes would be going ahead.

We understood that the Lords were due to discuss the matter on Monday 24 April, so we immediately sent the legal opinion to senior politicians in the House of Lords to inform the debate.

Later that evening press reports suddenly emerged that the proposals were to be dropped, and the next day we received a bulletin from the MoJ stating: ‘There is not enough time for the Statutory Instrument which would introduce the new fee structure to complete its passage through parliament before it is dissolved ahead of the general election. This is now a matter for the next government.’

Success…for now…

Our effort, and those of practitioners across the country, to highlight the issue had paid off. The legal uncertainty highlighted by Richard Drabble QC, combined with the media attention, meant that it could not be pushed through the Lords in time.

We have since heard from senior sources in the Lords that the subject may re-surface as primary legislation post-election, in which case it would need to be approved by both Houses of Parliament. We presume it would be re-introduced as a new tax, rather than an increased fee. If so, the funds will go to the Treasury, not the MoJ.

STEP will continue to work closely with our members and the media to increase awareness of the matter, although we sincerely hope it will not re-emerge in a different guise.

Emily Deane TEP is STEP Technical Counsel

Probate fees – will common sense prevail?

George HodgsonThe government’s threat to radically increase probate fees next month (Probate fee rise ‘a new tax on bereaved families’) may be receding, following a meeting of the House of Commons Joint Committee on Statutory Instruments on 29 March.

Using some very welcome common sense, the committee raises the issue (para 1.12) that it is a constitutional principle that there should be ‘no taxation without the consent of Parliament’. This is something I suspect 99% of people will agree with.

It finds that the proposal from the Ministry of Justice (MoJ) is clearly a tax, not a fee, in every normal definition of the term, and should therefore be subject to full parliamentary scrutiny, rather than brought in via the back door through a Statutory Instrument.

The committee also finds (para 1.13) that ‘charges’ of the magnitude proposed by the MoJ were probably never envisaged when the original legislation the government was attempting to use here was approved. In other words, using this process is an abuse.

We would hope that this will provide an opportunity for the government to re-think its approach, which was criticised by over 90% of those responding to the consultation, and submit re-worked proposals for proper scrutiny by Parliament.

• Joint Committee on Statutory Instruments: Non-Contentious Probate Fees Order 2017

 

George Hodgson is Chief Executive of STEP

New probate fees: FAQ

UPDATE 21/04/2017: the Ministry of Justice has conceded that the new fee regime has been abandoned due to lack of parliamentary time. See more information.

 

Newcastle District Probate Registry has supplied the following FAQs to help practitioners implement the new probate fees.

Q. What happens in cases where there is a need for an HMRC Assessment will any delay mean I incur the higher fee?

In cases where you are required to submit an IHT 400 or any IHT document for assessment by HMRC for Inheritance tax purposes then it is possible for you to submit the appropriate forms to both HMRC and HMCTS Probate simultaneously. We will not issue your grant until the approved IHT 421 is received but we will mark your application as lodged. To assist us in not raising this as a query it would be advisable to clearly mark your application that the IHT document will follow after assessment.

Q. Do we have the actual date of implementation?

No we do not have the actual date of commencement yet. However we can assure you that on receiving that date a mail shot will be released immediately informing you of that date. HMCTS Probate would however like to work with you now to ensure that we reduce as much as possible the added burden on applications nearer that date. You can assist us in doing this by following the steps in the mail shot sent to you on Monday 6th March.

Q. How do I calculate the estate value that the fee will be charged upon?

The fee is calculated from the net value of the estate after deducting liabilities or debts from the total of assets and gifts – you can do this using the appropriate Inheritance Tax form.

  • On an Inheritance Tax Summary Online application this figure will be the figure noted in the net estate value box
  • On form IHT 205 the net estate value for fees purposes can be found at Box F
  • On form IHT 207 the net estate value for fees purposes can be found at Box H
  • On form IHT 421 the net estate value for fees purposes can be found at Box 5

Q. What is considered as a full application?

A full application for Probate purposes and therefore to qualify for the appropriate fee is defined as the following. It must include:

  • An full oath sworn by all deponents and commissioners
  • An original will and codicil(where appropriate) endorsed by all commissioners and deponents
  • The appropriate number of correct copy wills an codicils
  • An Inland Revenue account (with the exception of IHT 400’s/421’s where assessment is ongoing and it has been noted on the covering letter that it will follow)
  • All associated documents including any affidavit evidence required at the time of submission, renunciations, Powers of attorneys
  • The appropriate fee.

Upon receipt of an application in this form prior to commencement then the existing fee will be charged.

Settlers and Prelodgements are not considered as full applications and therefore submission of an oath for settling prior to commencement and a subsequent oath after commencement will result in the new fee being applied.

Q: When will the new fees be implemented – at date of death or date of application?

The new fees will apply to all applications received by the probate service on or after the implementation date of the new fees irrespective of the date of death. Any application received within working hours of the Probate Registry before the implementation date will be charged the current fee. Subject to approval of the necessary legislation by Parliament, we expect the new fees to take effect from May 2017, but the exact date will be confirmed nearer the time.

Q Is there to be any equivalent of the IHT instalment option for an asset rich / cash poor estates?

There will not be an instalment option available to pay fees. If the estate does not have enough cash to pay the fee, executors will be able to apply to the Probate Service to access a particular asset for the sole purpose of paying the fee.

Q. How does the new fee affect property held between cohabitating couples?

The law remains the same. Any jointly owned assets (e.g. property held as joint tenants) will not require probate, regardless of whether couples are married, in a civil partnership or neither. All couples are free to choose how they hold their property, and they can change to a joint ownership arrangement via the Land Registry.

HMRC: no more safe havens

Treasure chestThis week STEP hosted a seminar to update members on HMRC’s latest moves to tackle tax evasion and avoidance.

Entitled, ‘An essential update on HMRC’s activity to tackle tax evasion and avoidance, including information exchange, new powers and its impact on professional advisors,’ the seminar took place at BDO LLP’s office in London. Speakers included John Shuker from the HMRC International & Offshore Evasion Team, and Dawn Register TEP of BDO LLP.

The introduction of the Common Reporting Standard (CRS) this year follows a raft of governmental efforts including the Foreign Account Tax Compliance Act (FATCA) and the EU Directive 2003/48/EC (the EU Savings Directive) to improve cross-border tax compliance. The Offshore Evasion Team has focused on clamping down on UK tax evaders, in particular:

• Moving UK gains, income or assets offshore to conceal them from HMRC
• Not declaring taxable income from overseas, or taxable assets kept overseas
• Using complex offshore structures to hide beneficial ownership of assets.

The tax gap for 2014-2015 is estimated to be GBP36 billion, with GBP 5.2 billion attributed to tax evasion.

HMRC launched the campaign ‘No Safe Havens’ in 2013 with the objective of ensuring that there are no jurisdictions where UK taxpayers can hide their income and assets. It also implemented a number of disclosure facilities to give people the incentive to come forward and pay tax voluntarily, before they are detected and sanctioned.

In the last two years, HMRC has vigorously escalated its tax evasion strategy. The Worldwide Disclosure Facility opened last September, in addition to a new requirement for all financial institutions and tax advisers to notify their customers about new automatic exchange of information agreements.

The following further measures are due to be implemented in 2017:

Corporate Criminal Offences of Failure to Prevent Facilitation of Evasion
This will apply to corporations who fail to prevent their agents from criminally facilitating tax evasion (facilitating evasion is already considered a criminal offence). The offences will apply to domestic or overseas corporations whose agents facilitate the evasion of UK taxes, or a domestic corporation which facilitates the evasion of tax overseas.

Tackling Offshore Tax Evasion: A Requirement to Correct
Taxpayers will be obliged to disclose any outstanding UK tax related to offshore investments or assets, or face ‘failure to correct’ penalties. These penalties will be significantly higher than for those who voluntarily put their affairs in order, and will be a minimum of 100%.

STEP’s Technical Committee has submitted responses to a variety of HMRC’s consultation papers relating to tax evasion below:

 

Emily Deane TEP is STEP Technical Counsel

How to win a STEP Private Client Award

George HodgsonEntries are open for the 2017/18 STEP Private Client Awards until 28 April 2017. The Awards are widely acknowledged as being one of the premier events in the private client industry calendar. Winning an Award is also a very clear and recognised hallmark of excellence.

How then, do you go about winning an Award?

Enter
The Awards are free to enter (we simply ask entrants to consider a donation to charity) and open to all firms and practitioners in the industry.

There can sometimes be a perception that the Awards are only for larger firms, but almost every year smaller firms impress the judges by demonstrating innovation, an exceptional focus on a particular area or an outstanding rapport with their clients. Applications from all sizes and types of firm are therefore welcome.

Similarly potential entrants away from the major industry centres sometimes feel they might be disadvantaged. The judges for the awards are nevertheless increasingly international and drawn from across the spectrum of the private client industry. Strong entries will always attract attention from the judges, wherever they originate from.

Don’t just copy and paste from marketing materials!
You will be judged by fellow senior industry professionals and the language and tone of your entry needs to reflect that fact. Cutting and pasting from your website or marketing material will usually not impress the judges. Neither will excessive use of superlatives and hyperbole. What will go down well is an evidence-based entry that gives a clear exposition of what the firm has done over the past year to make it stand out from the crowd.

Apply for the right award
It is a constant surprise to the judges how many firms enter the wrong category. One submission even began with the bold statement: ‘We are a leading (another category all together) firm…’. Read the category criteria carefully, and if you think the judges might have difficulty understanding why you are applying for a particular category, help them by explaining your business better.

Answer the questions
Probably the most common reason for submissions going by the wayside is that the judges feel that the questions and criteria laid down in the Awards entry pack have not been answered. It is standard advice to every student sitting an exam to read the questions carefully and make sure you answer them. The same holds true for anyone drafting a submission for a Private Client Award. There are typically five criteria on which each award will be judged. Judges are asked to score entries on each of those criteria, with each carrying equal weighting. If your entry does not cover one of the criteria, you are likely to be penalised.

Give examples and evidence
Solid evidence and real examples demonstrating why you think your firm deserves an Award always go down well with the judges. To illustrate, most entrants in most categories claim to be ‘client focused’, but some give real-life examples of how they achieve this and what they have done to go that extra mile for their clients. This attracts the judges’ attention far more than a simple assertion.

Be consistent
The judges are both curious and cynical in equal measure. They will check what you say in your submission against what you say on your website and other sources of information. Glaring inconsistencies tend to result in entries receiving relatively short shrift.

Know your (word) limits
Brevity is a strength, but submissions sometimes fall by the wayside because there is little clear detail on key issues and yet the submission is significantly below the 1,000-word limit. Equally, don’t go over your 1,000 words: the judges have a lot of entries to read!

Remember we are choosing ‘Xxx of the Year
Your firm may well be successful and very good at what it does, but the Awards are intended to highlight those that have achieved particular success over the past year. General statements about historic successes are therefore far less relevant than what you have actually achieved over the past 12 months.

From the above it is probably clear the STEP Private Client Awards are very competitive. Submissions across the board are usually of a very high standard. That is why the Awards remain so prestigious and the Awards Ceremony on 6 September 2017 remains one of the networking highlights of the year for many senior practitioners.

George Hodgson is Chief Executive of STEP

Are you a Trust or Company Service Provider under Schedule 23?

UK Emily Deane TEPHMRC has confirmed today that firms that advise their clients on the establishment of offshore companies or trusts may receive pre-Notice letters this month.

The letter requests that advisors come forward and volunteer the following information to HMRC: name and address of the client, the entity details (name, jurisdiction, date of registration) and details of persons with beneficial ownership or interest in the entity. Following the issue of the pre-Notice letters the formal Notices will be issued under Schedule 23 of the UK Finance Act 2011 in February 2017.

STEP and the Law Society of England & Wales have been in protracted talks with HMRC about this issue over the last year. There are concerns about the potential breach of legal professional privilege, access difficulties to the relevant data and the definition of Trust or Company Service Providers (TCSPs).

HMRC has launched this initiative in order to gather information on the beneficial ownership of offshore companies and beneficial interest in offshore partnerships, trusts and other entities from UK-based TCSPs or their overseas subsidiaries. However, the definition of a TCSP in this connection is a little uncertain. The Money Laundering Regulations 2007 (MLR) incorporate the meaning of a TCSP within regulation 3:

’10) “Trust or company service provider” means a firm or sole practitioner who by way of business provides any of the following services to other persons—

(a) forming companies or other legal persons;

(b) acting, or arranging for another person to act—

      (i) as a director or secretary of a company;

      (ii) as a partner of a partnership; or

      (iii) in a similar position in relation to other legal persons;

(c) providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or arrangement;

(d) acting, or arranging for another person to act, as—

      (i) a trustee of an express trust or similar legal arrangement; or

      (ii) a nominee shareholder for a person other than a company whose securities are listed on a regulated market,

when providing such services.’

We believe that the most likely scenario whereby a UK practitioner will be classed as a TCSP is under section 10(d) when the UK practitioner arranges for another person to set up the entity offshore. It is not entirely clear whether this would  be a formal referral to another firm, involving a transaction fee, or whether an informal recommendation of an offshore firm is sufficient to trigger the classification as a TCSP.

Regulation 6 of the MLR sets out in detail which persons should be treated as though they are beneficial owners for the purpose of Anti-Money Laundering. Those categories are:

  • any individual who is entitled to a specified interest in at least 25 per cent of the capital of the trust property
  • any trust, other than one which is set up or operates entirely for the benefit of individuals, falling within sub-paragraph (a) the class of persons in whose main interest the trust is set up or operates
  • any individual who has control over the trust.

There is a £300 penalty for initial non-compliance, followed by daily penalties of up to £60 if the non-compliance continues. The TCSP will have 90 days to respond with the requisite information.

We understand that the Notices are only being sent to a select number of firms in February and HMRC has not issued any guidance at this time, therefore please contact emily.deane@step.org if you have any queries.

Emily Deane TEP is STEP Technical Counsel