Taxation of Chargeable Gains Act 1992 section 271G

Exceptions: notices and information

Section 271G sets out the circumstances in which tax obligations and liabilities of a non-UK resident do not automatically pass to their UK representative, and limits the information-provision duties of independent agents acting as UK representatives.

• A UK representative only becomes subject to a non-UK resident's obligations if the representative has actually received the relevant notice, document, request or demand (or a copy of it)
• Where the UK representative is an independent agent, they are only required to provide information to HMRC so far as it is practicable for them to do so, having taken all reasonable steps to obtain the necessary information
• If the UK representative can only partially fulfil an information obligation due to practicability limits, the non-UK resident remains personally responsible for providing the full information
• The non-UK resident is not bound by mistakes in information supplied by the UK representative, unless those mistakes resulted from the non-UK resident's own act, omission, consent or connivance