Can I delay accounting for and paying VAT to HM Revenue & Customs on clients’ bills until I have received payment from the client?
No. The effect of HM Revenue & Customs Notice 700 is to make unlawful and ineffective the practice of a solicitor writing to a client to inform them of the fees but not issuing a VAT invoice until payment has been received.
The tax point for services is usually the date on which their performance is completed. VAT becomes payable on that date irrespective of when the bill is delivered.
There is an exception for solicitors in that, if a tax invoice is issued within three months of the basic tax point, the date of the invoice becomes the actual tax point. VAT is therefore payable by a solicitor when the work is completed or when the bill is delivered, provided that this is within three months of the completion of the work (HM Revenue & Customs Notice 700 and section 6(6) of the Value Added Tax Act 1994). It is an offence for a solicitor not to quantify the charges within three months of completing a matter for the purposes of calculating and paying VAT.
Our firm is considering becoming a home information pack (HIP) provider. Do the new Money Laundering Regulations 2007 apply to the provision of this service?
No. The new regulations, which came into force on 15 December 2007, contain a specific exclusion in regulation 4 (1)(f) regarding HIPs, which states: ‘These regulations do not apply to... a person, when he prepares a HIP or a document or information for inclusion in a home information pack’. Please see chapter 1 of the anti-money laundering practice note 2008 which is available on the Law Society’s website at www.lawsociety.org.uk.
I am a criminal solicitor and my client has just told me that he is not going to turn up at the trial. Does the Law Society have any guidance on what I should do?
The Law Society has issued a practice note dated 16 August 2007 entitled Criminal Procedure Rules: impact on solicitors’ duties to the client. You should certainly advise the client of the adverse effects of non-attendance, as mentioned on page 13 of the practice note. Ideally, this advice should have been put in writing in your initial letter of retainer.
Page 12 of the practice note points out that you have obligations to the court of which you are an officer, but only where this is consistent with your duties to your client. The practice note states that you can say you are without instructions but cannot disclose information about the client’s whereabouts. There may be circumstances where you can continue to act, but ultimately it is a matter for you, not the court, to decide whether or not you can properly continue to act.
You may also wish to contact Professional Ethics (0870 606 2577) to discuss your obligations under the Solicitors Code of Conduct, in particular rule 11.
I am seeking to recover costs from my client to the sum of £9,000. In which court do I commence proceedings?
You can only commence this action in the County Court. Proceedings cannot be commenced in the High Court unless the value of the claim is more than £15,000 (see part 7 of the practice direction supplementing CPR).
Our new firm is overhauling its policies and procedures to take account of the new Money Laundering Regulations which came into force on 15 December. Does the Law Society produce any sample/precedent client care letters?
You may wish to refer to the Law Society publication Your clients – your business (October 2007), which is available on the Law Society website at www.lawsociety.org.uk. While the publication does not contain sample letters, it does provide solicitors with a client care checklist and includes sample paragraphs, which you may wish to use as a basis for your client care letters. It also includes paragraphs on money laundering issues that have been approved by the Law Society Money Laundering Task Force.
What are the general penalties and potential redress for a breach of the Home Information Pack Regulations (No.2) 2007?
Practitioners can face a penalty notice of £200 for breach of the HIP regulations. The duties imposed by the regulations will be enforced by the local authority Trading Standards Officers under a civil sanctions regime.
Under the HIP (Redress) Order 2007 SI 560, all estate agents must, for matters relating to HIPs, belong to a compulsory redress scheme. The Consumer Estate Agents and Redress Act (CEARA) received Royal Assent on 19 July 2007. The Estate Agents (Redress Scheme) Order 2008 was laid in Parliament on 1 July 2008 and it will come into force on 1 October 2008. It will become compulsory for all estate agents to belong to a redress scheme and establish complaint-handling procedures in relation to all estate agency work. Part 3 of CEARA also provides for records to be maintained and to be made available for inspection by enforcement officers.
In respect of HIPs, the Ombudsman for Estate Agents HIPs Redress Scheme and the RICS Surveyors Ombudsman Scheme are the only recognised schemes for estate agents. Solicitor property sellers will be bound by a recent amendment to rule 18 of the Solicitors Code of Conduct 2007 concerning the conduct of property sellers, which to similar effect makes them accountable for complaints.
For further information, please refer to the Law Society publication Handling HIPs, which is available free of charge to members of the Property Section (£25 to non-members), at www.propertysection.org.uk.
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