The International Tax Compliance (Client Notification) Regulations 2016, SI 2016/899, came into force on 30 September 2016. Essentially, they create an obligation on certain financial institutions and specified relevant persons to give prescribed information to certain clients. Specified relevant persons (SRPs) include tax advisers and any other persons who in the course of business provide offshore advice or services, or refers individuals to a connected person overseas for offshore advice or services, in relation to their personal tax affairs. Many law firms will be SRPs. HMRC has, however, clarified that if the only advice or service you provide is to fill in and submit a tax return for a client, the rules are unlikely to apply. The notification obligation is most likely to impact on firms’ private client teams and notification letters are most likely to be sent by client partners, although compliance teams are likely to have to field enquiries about the requirements. HMRC has published guidance