Overseas entities that hold, want to buy, sell, or transfer property or land in the UK must register with Companies House and declare their registrable beneficial owners or managing officers. This requirement was introduced as part of the Economic Crime (Transparency and Enforcement) Act 2022. Companies should have registered by 31 January 2023. 

HMRC now has access to a vast amount of data from the ROE. However, gaps inevitably remain due to non-compliant overseas entities. Non-compliant entities may face monetary penalties or other sanctions. 

With this new data, HMRC is working to identify taxpayers who may have undeclared or incorrect UK tax liabilities as a consequence of their beneficial holdings. Affected taxpayers may be individuals or companies with the beneficial interest in UK property or land. 

On its LinkedIn page, HMRC is encouraging taxpayers who may have an undisclosed tax liability to get in contact using its new disclosure facility. Taxpayers who make unprompted voluntary disclosures may be subject to lower penalties than if HMRC makes first contact.  

While the ROE is very new, ICAEW members have reported already seeing activity from HMRC in this space. This indicates that HMRC is proactively using this data to target its compliance activity. 

Read more:  

• https://www.gov.uk/guidance/register-an-overseas-entity 
• What the Register of Overseas Entities means for accountants | ICAEW