UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs [Archived]
Produced in partnership with Ali Kazimi of Hansuke

The following Tax practice note produced in partnership with Ali Kazimi of Hansuke provides comprehensive and up to date legal information covering:

  • UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs [Archived]
  • What are the CDOT agreements?
  • What has happened to CDOT now that the Common Reporting Standard is live?
  • What did the CDOT agreements require entities to do?
  • Which agreements were reciprocal and imposed obligations on FIs in the UK?
  • What was the legal basis for introducing CDOT in the UK
  • When did CDOT go live and what are the key dates?
  • Penalties for Errors
  • What are the key differences from FATCA?
  • What is the alternative reporting regime?

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs [Archived]

ARCHIVED: This archived Practice Note provides information on the agreements entered into between the UK and its crown dependencies and overseas territories for the exchange of information on financial accounts, known as Crown Dependency/Overseas Territory (CDOT) Agreements and the reporting under those agreements for periods up to the end of 2016 before CDOT was superseded by the Common Reporting Standard (CRS), for which see Practice Note: Automatic exchange of information—the Common Reporting Standard: a summary.

What are the CDOT agreements?

The UK entered into agreements with its three Crown Dependencies (CDs) (Guernsey, Jersey and the Isle of Man), together with its Overseas Territories (OTs) (Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Montserrat, Turks & Caicos Islands) to provide details of financial accounts being held by UK tax residents (or passive investment companies controlled by such persons) in those jurisdictions. Collectively these agreements are known as the CDOT agreements, CDOT, or UK FATCA.

The catalyst for the agreements was the US Foreign Account Tax Compliance Act (FATCA). Each jurisdiction was seeking to enter an Intergovernmental Agreement (IGA) to implement FATCA. As these would be regarded as international treaties, they would require the permission of the UK. Accordingly, it was agreed that equivalent information to that being sent to the US would be passed to the UK.

They were enforced through IGAs that

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