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Who is the Client?

  • Member
  • Practice Licence
  • 3 posts
  • # 118911

Hi All

I have recently obtained my practice licence and am now seeking clients. My first potential lead is an enquiry I received from an investment adviser (he works for the company I have my private pension invested with).

The Adviser has clients who need help with Capital Gains Tax calculations and returns as well as Self-Assessment Tax Returns. This seems fine but he has said that he would be paying the accountancy/bookkeeping invoice on his client's behalf. Would this mean that I need to carry out AML checks on the investment Adviser who is providing the clients AND the individuals concerned? Who would be the actual client? 

Thanks for any guidance in advance.

  • Member PM.Dip
  • 16 posts
  • # 118919

Hi Steve


The client is essetnially the person that you are providing the service for directly, so the advisor will in fact be YOUR customer but it all depends on if he employs you to do the work or he is hiring you to do the work !!

I'm not sure about the AML checks but im guessing you would not need to do that so called 'legal' side of things, that would be more what his supported instituion deals with....

The fact that the advisor has his own clients/customers is irrelevant to you it just sounds like the advisor is getting you to do the work that he does not have time to do himself (but like i meantioned above you need to establish if he is employing you, like a accountancy practice or he is hiring you as a self-employed worker because Tax and NICs are differently recorded).

but not sure how the advisor can pay you and also pay the invoice on the client's behalf, that sounds like he is paying twice??




  • Member
  • Practice Licence
  • 3 posts
  • # 118937

Thanks for replying Andy

The adviser's professional body is not an MLR supervisory body (in fact, a search of their website for anything regarding Money Laundering Regs turns up 0 items - bit of a worry). 

I am trying to get some clarification on his requirements but yes, it sounds like he would be hiring my services on a self-employed basis. He would pay my invoice but his client would pay any tax that was actually due after submitting the return.


Best regards


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