Finance (No. 2) Act 2015

50 International agreements to improve compliance: client notification

(1) Section 222 of FA 2013 (international agreements to improve tax compliance) is amended as follows.

(2) In subsection (2), in paragraph (c), after “purposes” (but before the closing bracket) insert “and client notification obligations”.

(3) In subsection (2), after paragraph (c) insert—

“(ca) impose client notification obligations on specified relevant persons;”.

(4) After subsection (2) insert—

“(2A) For the purposes of subsection (2)(c) and (ca) a “client notification obligation” is an obligation to give specified information to—

(a) clients, or

(b) specified clients.

(2B) In subsection (2A) the reference to an obligation to give specified information includes—

(a) any obligation to give the information—

(i) in a specified form or manner;

(ii) at a specified time or specified times;

(b) in the case of a relevant financial entity or relevant person which is a body corporate, an obligation to require a person of which it has control to give the information.”

(5) In subsection (4), at the appropriate places insert—

• ““client” includes—

  (a)

  any client or customer, and

  (b)

  any former client or customer;”;

• ““control” is to be construed in accordance with section 1124 of CTA 2010;”;

• ““relevant person” means—

  (a)

  a tax adviser (as defined by section 272(5) of FA 2014), and

  (b)

  any other person who in the course of business—

  (i)

  gives advice to another person about that person’s financial or legal affairs, or

  (ii)

  provides other financial or legal services to another person;”.