Tax tripe and onions

 In Analysis, Information, Legislation

In order to function in todays world, it seems that you need to master a number of perversions of the English language.


For example, I have to admit that I cannot find the reset button on the dashboard of my car. Vehicle guidebooks are invariably written in Motor Industry Mumblecore. All people in the automotive industry speak it fluently, but it is impenetrable to oiks like me who drive the cars. Whatever I am looking for help on, it is always found somewhere else in the book, nowhere near where I would expect to locate it, and expressed in the purest car jargon.

Recently, one of my clients passed on to me a letter from HM Revenue and Customs which seemed to set new standards in incomprehensibility. I have taken out names, addresses, and other confidential information and reproduce it below:

Dear Ms X,

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations), XXXX Limited (the Business)

Company Number: XXXXX

Intention to Cancel Registration

I am writing to notify the Business of my intention to cancel its registration for the following reasons:

  1. I suspect that the Business will fail to comply with its obligations under the Regulations. This is due to the Business failing to add responsible persons to the registration. A ‘responsible person’ is a beneficial owner, officer or manager of the Business.

Regulation 26(1) states that no person may be the beneficial owner, officer or manager of an estate agents unless that person has been approved by HMRC. As the Business has one individual acting as a Responsible Person who has not been approved or applied for approval, the Business has failed to comply with Regulation 26(1) and 26(7).

Under Regulation 60(3)(a), HMRC may cancel a registration in a register maintained by it under Regulation 55 if, at any time after registration, it appears to HMRC that any paragraphs of Regulation 59(1)(a) to (e) apply. As the Business has failed to comply with Regulations 26(1) and 26(7), I believe it is reasonable to suspect that the Business will continue to fail to comply with its obligations under the Regulations and therefore Regulation 59(1)(e)(i)(aa) applies.

2. The Business has failed to meet the requirements of the Regulations. This is due to the Business not paying charges imposed on it under Regulation 102(1)(a) by HMRC.

As of 01 November 2017, all responsible persons within businesses such as this which are supervised by HMRC are subject to an approval check under Regulation 26 with a charge of £40 per person imposed by HMRC under Regulation 102(1)(a).

Under Regulation 60(3)(a), HMRC may cancel a registration in a register maintained by it under Regulation 55 if, at any time after registration, it appears to HMRC that any…. (here there was text missing from the HMRC letter.)

However, if I do not hear from you or the Business within 14 days after the date of this letter, I will issue the decision to cancel the Business’s registration.

If the Business chooses to contact me about this case, it will need to quote the reference shown at the head of this letter. If writing to me, please use the address shown above. If documents are sent, it must tell me if it wants them to be returned; as we may securely destroy them after 50 days.

If the Business is unclear about any of the matters I have raised or needs more help, please contact me using the details at the top of this letter.

Yours sincerely,
Officer of HM Revenue & Customs
Anti-Money Laundering Supervision


And this is how I would have asked for the information needed if I were HMRC:

Dear Sirs,

Anti-money laundering supervision.

We are writing this letter in our capacity as your anti-money laundering supervisors.  Please note that this letter has no relevance to your personal or business tax affairs.

Our records indicate that on (date) you contacted us by logging onto our system and appointing us as your anti-money laundering supervisor under section (xx) of the (xxx) act, (xxxx) and subsequent regulations.  At that time the system should have asked you for details of company officers and senior staff, including the company secretary.  Unfortunately the name of the company secretary appears to have been omitted.

We request that you log onto our system and update the details of your business, in particular those of the responsible persons in your organisation.

Please will you do this by (date) to ensure that your supervision can continue.

The regulations governing this request can be found on our website under (wherever).  Alternatively, if you have any questions you may wish to seek professional advice.

Thank you in advance for your kind co-operation. 

Yours faithfully.”


My client, and his employee who was quite startled by the HMRC letter, agree that they would have been a lot less confused if HMRC had worded it differently.

It has been noted, by people far wiser than me, that human affairs are getting more complex all the time, such that only the insiders, or the extremely clever, can understand what is happening.

If HMRC would like a little help with their communications to the outside world, I would gladly offer my services.

– Stephen Handley

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