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HMRC one to many letters and briefings

HM Revenue and Customs (HMRC) has shared several briefings about one to many (OTM) letters with the Law Society and other members of the HMRC-sponsored Wealthy External Stakeholder Forum.

Each briefing is about a specific OTM letter. HMRC is using these OTM letters to communicate standard, common messages to multiple taxpayers.

HMRC’s aim is to influence taxpayers’ behaviour, so they are more likely to comply with their tax obligations. You can read more about this approach in HMRC's Compliance Manual.

HMRC is sending letters directly to individuals and/or separate letters to their agent where the taxpayer is represented.

HMRC has told us that the dates in the briefings are approximate and are subject to change given the constantly changing circumstances at the time of writing.

With HMRC’s permission, we share these HMRC briefings below, which include embedded copies of the letters.

Omitted capital gains tax (CGT) briefing (1 October 2020)

This briefing is about OTM letters being sent to taxpayers who, according to HMRC’s information, have disposed of a property which was not their primary residence but have not declared any CGT in respect of the proposal. It asks them to consider their CGT position in respect of the disposal.

There are two versions of the proposed letters depending on whether or not individuals involved have filed a self-assessment tax return.

Download the briefing on omitted capital gains tax (Word 508 KB)

Deferred consideration briefing (7 October 2020)

This briefing is about OTM letters being sent to taxpayers who HMRC believes may have received deferred consideration in connection with a sale of shares in an unlisted company.

Download the briefing on deferred consideration (Word 159 KB)

ATED non-filers briefing (13 October 2020)

This briefing is about OTM letters to corporates who appear to have purchased a dwelling or residential property worth more than £500,000 from 1 April 2020 and have not filed an ATED (annual tax on enveloped dwellings) return.

Download the briefing on ATED non-filers (Word 138 KB)

Investment income discrepancies briefing (15 October 2020)

This briefing is about OTM letters that are being sent in cases where information HMRC receives from financial institutions about individuals’ investment income does not match the information on their self-assessment tax return.

Download the briefing on investment income discrepancies (Word 317 KB)

Benefits in kind discrepancies briefing (14 October 2020)

This briefing is about OTM letters being sent in cases where there are discrepancies between HMRC’s information from employers and from employees’ self-assessment tax returns about employee benefits in kind.

Download the briefing on benefits in kind discrepancies (Word 341 KB)

Pay and tax discrepancies briefing (23 October 2020)

This briefing is about OTM letters being sent in cases where there are discrepancies between HMRC’s information from employers and from employees’ self-assessment tax returns about on employees’ pay and tax.

Download the briefing on pay and tax discrepancies (Word 318 KB)

Persons of significant control briefing (23 October 2020)

This briefing is about an OTM letter being sent to individuals who are named as a person of significant control of a mid-sized business highlighting some common errors and inviting them, if necessary, to amend their tax returns.

Download the briefing on persons of significant control (Word 405 KB)

Residential property CGT briefing (23 October 2020)

This briefing is about OTM letters being sent where HMRC has identified a potential incorrect declaration of residential property disposals in taxpayers’ self-assessment tax returns. 

Download the briefing on residential property CGT (Word 394 KB)

Outstanding self-assessment returns briefing (23 October 2020)

This briefing is about OTM letters being sent to taxpayers who have received a notice to file a self-assessment tax return for 2017/18 but are yet to submit a return.

Download the briefing on outstanding self-assessment returns (Word 252 KB)

Statutory residence test briefing (26 October 2020)

This briefing is about OTM letters being sent with a view to educating taxpayers about the statutory residence test.

Download the briefing on the statutory residence test (Word 214 KB)

Deemed domicile briefing (2 November 2020)

This briefing is about OTM letters being sent in cases where taxpayers may have become deemed domiciled in the UK from 6 April 2017 under legislation introduced in Finance (No.2) Act 2017.

Download the briefing on deemed domicile (Word 703 KB)

Foreign tax credit relief briefing (11 November 2020)

This briefing is about OTM letters being sent by HMRC about the conditions and eligibility criteria for claiming foreign tax credit relief against employment income.

Download the briefing on foreign tax credit relief (Word 234 KB)

Overseas workdays relief briefing (11 November 2020)

This briefing is about OTM letters that seek to educate taxpayers who are seconded to work in the UK by an overseas employer about the conditions for claiming overseas workdays relief.

Download the briefing on overseas workdays relief (Word 240 KB)

Residency briefing (11 November 2020)

This briefing is about OTM letters being sent to inform taxpayers about making claims for relief under a double taxation agreement, focusing on the relevant documentation that should be completed.

Download the briefing on residency (Word 230 KB)