FATCA in the UK—the UK:US Intergovernmental Agreement: an outline
Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited
FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

The following Tax practice note Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited provides comprehensive and up to date legal information covering:

  • FATCA in the UK—the UK:US Intergovernmental Agreement: an outline
  • Background to FATCA
  • Background to the ‘intergovernmental approach’ and ‘model agreements’
  • UK FATCA
  • Background to the UK:US IGA
  • Framework of the UK:US IGA and International Tax Compliance Regulations
  • Who can rely on the UK:US IGA?
  • What is a reporting financial institution?
  • Custodial institutions
  • Investment entities
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May 2020 due to difficulties arising from the coronavirus pandemic, HMRC will accept that the institution has reasonable excuse and will not levy a penalty for the late report, provided it is made without unreasonable delay after the difficulties are resolved.

This Practice Note provides a broad overview of:

  1. the Intergovernmental Agreement between the UK and the US to improve international tax compliance and to implement FATCA signed on 12 September 2012 (the UK:US IGA), and

  2. the International Tax Compliance Regulations 2015, SI 2015/878 (the International Tax Compliance Regulations) so far as they concern the implementation of the UK:US IGA

The International Tax Compliance Regulations came into force on 15 April 2015. They replace and revoke the International Tax Compliance Regulations

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