Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Undisclosed definition

What does Undisclosed mean? Undisclosed factoring describes a receivables finance arrangement where a business assigns its invoices to a factor but does not tell the debtor until the factor later serves notice. In practice, the client continues to issue invoices and collect payments, usually as the factor’s agent or trustee, paying proceeds into a controlled account. Also called confidential or non-notification factoring, this is a descriptive market term rather than a defined statutory concept. Key legal features and risks: until notice of assignment is given, the debtor can validly pay the client. In England and Wales and Northern Ireland, the assignment...

UK HMRC Requirement to Correct on offshore tax non-compliance: scope, time limits, IHT, trustees/companies, penalties, reasonable excuse, and interested person rules (Finance (No 2) Act 2017)

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Practice notes

What is the requirement to correct?

The statutory footing for the requirement to correct (RTC) sits in section 67 and Schedule 18 of the Finance (No 2) Act 2017 (F(No 2)A 2017). It obliged taxpayers with ‘relevant offshore tax non-compliance’—that is, undeclared UK income tax, Capital gains tax (CGT) or Inheritance tax (IHT) Liabilities arising from offshore interests—to put matters right by notifying HMRC of any unpaid tax no later than 30 September 2018. HMRC’s RTC guidance explains that 30 September 2018 was selected as the final correction date because, by then, over 100 jurisdictions were scheduled to share financial account information under the Common Reporting Standard (CRS). For background on the CRS, see Practice Note: Automatic exchange of information—the Common Reporting Standard: a summary. Those who did not provide the necessary disclosure to HMRC on or before 30 September 2018 became exposed to a new penalty for a failure to correct (FTC). The FTC charge is set at 200% of the ‘offshore PLR’ (potential loss of revenue) attributable to the continuing offshore tax non-compliance. What counts as PLR depends on the statutory context, taxpayer behaviour, relevant time limits, and the classification of offshore matters set out in HMRC guidance and applicable...

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Web page updated on 22/05/2026

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