The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own...
The Common Reporting Standard (CRS) is a global standard under which participating jurisdictions agree to exchange information about financial accounts held by...
FORTHCOMING CHANGE: The EU Fifth Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force on 9 July 2018. The...
ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage of the Bill through Parliament to its publication as an Act, and highlighted key...
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....
The Crown Dependencies of Jersey, Guernsey and the Isle of Man, and the Overseas Territories of Bermuda, Cayman Islands and British Virgin Islands, have all introduced...
Introduction The government’s strategy for tackling offshore tax evasion was initially set out in HMRC’s 2014 No Safe Havens and has been supplemented by HMRC’s No Safe...
EU Directive 2018/822 of 25 May 2018 (DAC 6) requires Member States to enact rules obliging ‘intermediaries’ (as defined), and in some cases taxpayers, to report...
This Practice Note discusses the two ‘failure to prevent’ corporate criminal offences created by the Criminal Finances Act 2017 (CFA 2017): • CFA 2017, s 45 creates the...
This Practice Note provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for private client practitioners and contains links to more detailed...
This Practice Note considers the application of the Foreign Account Tax Compliance Act (FATCA) to UK Trusts, as implemented in the UK by the International Tax Compliance...
At a very high level, certain provisions of the US Internal Revenue Code of 1986, as amended (the Code), commonly known as FATCA, seek to encourage foreign (ie non-US)...
This Practice Note provides a broad overview of: • the Intergovernmental Agreement between the UK and the US to improve international tax compliance and to implement...
The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility that extended to all main taxes including, but not limited to, income tax, corporation...
STOP PRESS: On 10 January 2020, the Fifth Money Laundering Directive (EU) 2018/843 (MLD5) was transposed in the UK through changes made to the Money Laundering, Terrorist...
FORTHCOMING CHANGE: The fifth anti-money laundering directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force on 9 July 2018. The...
FORTHCOMING CHANGE: The Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), which received Royal Assent on 23 May 2018, provides a power for Ministers to make...
Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provide a limited opportunity for individuals to...
FORTHCOMING CHANGE: Following a consultation by HMRC which ran from 19 February 2018 to 14 May 2018, the government has included legislation in the Finance Bill 2019 to...
Background to the strict liability offences for offshore tax evaders The government’s strategy for tackling offshore tax evasion was initially set out in HMRC’s 2014 No...
FORTHCOMING CHANGE: On 6 July 2018, draft legislation was published for inclusion in Finance Bill 2019 to extend the tax assessment time limit (during which HMRC may...
What is the requirement to correct? The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance (No 2) Act 2017...
This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs). For guidance on the OECD's Multilateral Convention on Mutual...
This tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA). The tracker is split into five parts: • US...
Corporate transparency is now viewed as an essential element in any strategy aimed at reducing or eliminating corruption, tax evasion, terrorist financing and money...
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual Administrative...
What are crypto-assets? One of the hurdles in relation to understanding non-traditional currencies and assets lies in the inconsistent use of language. Regulators and tax...
FORTHCOMING CHANGE: The EU Fifth Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force on 9 July 2018. The...
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...
On 6 October 2011, the governments of Switzerland and the UK signed an agreement to co-operate on tax matters entitled the UK-Swiss Confederation Taxation Cooperation...