Apologies, I am confused here. (TL;DR: Skip to the last sentence of the post for my actual question). I got a ROS notification today about "Reviewing and Correcting Your Tax Returns". I presume this is the vanilla letter sent to all self-assessed individuals, and not particularly singling me out. I followed the link to
Revenue's web page on 'Making a Disclosure'. There I see the the items of interest are:
- an account held or situated in a country or territory other than the State
- income or gains arising from a source, or accruing, in a country or territory other than the State
- property situated in a country or territory other than the State.
I also note from a document linked from the Revenue page ('[broken link removed]'):
2.1 Is it illegal to have offshore accounts, assets or investments?
No, it is not illegal to have an offshore account or to have assets or investments offshore, but you
must pay tax on any interest, income or gains earned. Also, any money placed in an offshore account
or used to acquire assets or investments offshore must be declared for tax purposes, unless exempt
from tax or Irish tax has already been paid on it.
2.2 I have money offshore does that mean I have a tax problem?
If all the money you put offshore has already been declared for Irish tax purposes and you have
declared all income or gains arising from that money on your tax returns, you have no further
liability and you do not need to make a disclosure.
If you have opened an offshore account or acquired a financial product with monies that are exempt
from tax or on which the correct Irish tax has already been paid and have not earned any income on
the account or financial product itself, you have no tax liability
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So here's my thing: I have a euro trading account with SaxoBank UK. In theory I can see how this could qualify as an 'offshore account', as there are actually cash sums in there, albeit not earning any interest. All original income taxes were paid on the amounts transferred to the Saxo account. All of my gains from trades are 100% reported and up to date -- I pay all CGT by the payment deadlines and file a tax return as soon as possible, usually on January 1st, ten months ahead of the filing deadline. Items are declared as capital gains, UK dividends etc. as appropriate per Form 11. I have maintained exquisitely detailed spreadsheet records of all trades, calculated gains and tax returns, separate from the account statements themselves. As far as I'm concerned my tax affairs go beyond 'ultra-squeaky clean'.
So my only concern is that I have not declared a Saxo UK trading account itself as an offshore account. Do I need to? I have been presuming not.