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Register of Overseas Entity deadline approaches


Published: 13 Dec 2022 Update History

Overseas entities that own land or property in the UK are required to declare their beneficial owners by 31 January 2023.
As part of the Economic Crime (Transparency and Enforcement) Act 2022, certain entities will need to be registered on the Register of Overseas Entities (ROE) by 31 January next year (2023).

Broadly, this includes overseas entities that already own or lease land or property in the UK. It also includes entities that want to purchase or sell land or property in the UK. Affected entities must declare their beneficial owners or managers on the ROE within set time limits.

Additional information can be found on Companies House. HMRC has also published a policy paper setting out considerations from a tax perspective.

Accountants are able to undertake verification work in relation to the ROE. However, ICAEW advises firms to think very carefully before they offer a verification service. As ICAEW has previously set out in ICAEW Insights, ICAEW members and member firms will have strict liability of providing verification services for any entity registering on the ROE. As it currently stands, a firm could be liable to prosecution if they verify documents that turn out to be false, even though there is no malicious intent. Firms should consider the AML risks associated with undertaking verification work.
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