Crown Dependency Disclosure Facilities [Archived]
Crown Dependency Disclosure Facilities [Archived]

The following Private Client practice note provides comprehensive and up to date legal information covering:

  • Crown Dependency Disclosure Facilities [Archived]
  • Who is eligible to participate in the Crown Dependency Disclosure Facilities?
  • Who is not eligible to participate in the Crown Dependency Disclosure Facilities?
  • Benefits of disclosure under the Crown Dependency Disclosure Facilities
  • Procedure and time limits
  • Tax, interest and penalties
  • The four year concession re error in tax returns

ARCHIVED: This Practice Note has been archived and is not maintained.

In October 2013, the Isle of Man, Jersey and Guernsey each signed inter-governmental agreements (IGAs) with the UK to implement the automatic exchange of tax information. These agreements are sometimes referred to as ‘UK FATCA’ as they closely follow the disclosure provisions and timetable of the US Foreign Account Tax Compliance Act.

Under the IGAs, financial institutions in the Isle of Man, Jersey and Guernsey are required automatically to report financial information on UK resident individuals, partnerships and companies to HMRC from January 2015. Information for the 2014 and 2015 calendar years must be reported by 30 September 2016 and, from then on, reporting is due within nine months of the end of the relevant calendar year. These agreements are due to be replaced by the Common Reporting Standard. See Practice Note: Automatic exchange of information—the Common Reporting Standard: a summary—Automatic exchange of information in the British Crown Dependencies and Overseas Territories.

The Isle of Man, Jersey and Guernsey disclosure facilities (referred to hereafter as the IOMDF, JDF and GDF) were introduced by HMRC to enable those with irregularities in their tax affairs to set their affairs in order prior to the automatic exchange of information. The disclosure facilities ran from 6 April 2013 until the end of 2015. They were originally intended to run until

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