The International Tax Compliance Regulations 2015

Made: 24th March 2015

Laid before the House of Commons: 25th March 2015

Coming into force: 15th April 2015

The Treasury make these Regulations in exercise of the powers conferred by section 136 of the Finance Act 2002 and section 222(1), (2) and (3) of the Finance Act 2013 :

Introductory

Citation, commencement, effect and interpretation

1

• (1) These Regulations may be cited as the International Tax Compliance Regulations 2015 and come into force on 15th April 2015.

• (2) These Regulations have effect for and in connection with the implementation of obligations arising under the agreements and arrangements listed in paragraph (3) and apply separately in relation to each of those agreements or arrangements except where the context otherwise requires.

• (3) The agreements and arrangements are—

• (a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (aa) the OECD (2014), Standard for Automatic Exchange of Financial Account Information in Tax Matters as amended by the 2023 update to the Common Reporting Standard contained in the OECD (2023), International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023 update to the Common Reporting Standard, including the commentary (the “CRS”);

• (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (c) the agreement reached between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to improve international tax compliance and to implement FATCA, signed on 12th September 2012 and amended in June 2013 and February 2019 (“the FATCA agreement”).

• (3A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (4) These Regulations have effect from—

• (a) 1st January 2016 in relation to ... the CRS, and

• (b) 15th April 2015 in relation to the FATCA agreement.

• (5) In these Regulations, a reference to “relevant agreement” means such agreement or arrangement referred to in paragraph (3) as the context requires, as that agreement or arrangement has effect from time to time.

• (5A) For the purposes of these Regulations—

• (a) “financial institution” has the same meaning in relation to the FATCA agreement as it does in section 1.1471-5(e)(1)(i)-(iv) of the US Treasury Regulations, and

• (b) “investment entity” has the same meaning in relation to the FATCA agreement as it does in the US Treasury Regulations.

• (6) Any expression which is defined in a relevant agreement but not in section ... 235 of FA 2013 or in these Regulations has the same meaning in these Regulations as in the relevant agreement.

• (7) In its application for the purpose of these Regulations, the CRS is to be read as if—

• (a) the optional wording in paragraph 36sexies of the commentary to Section VIII of the CRS adding the term “qualified non-profit entity” were included in the definition of “non-reporting financial institution” at sub-paragraph B(1)(f),

• (b) the optional wording in paragraph 36sexies of the commentary to Section VIII of the CRS defining the term “qualified non-profit entity” were included at sub-paragraph B(10), and references in that wording to “Jurisdiction” were a reference to the United Kingdom,

• (c) the published list referred to in Section VIII(D)(4)(ii) (definition of reportable jurisdiction) were the list contained in a notice published by the Commissioners further to this regulation, and

• (d) the published list referred to in Section VIII(D)(5)(ii) (definition of participating jurisdiction) were the list contained in a notice published by the Commissioners further to this regulation.

Meaning of “reportable account”

2

• (1) In these Regulations, a “reportable account” means—

• (a) an account which is a reportable account within the meaning of the relevant agreement,

• (b) in relation to a reporting financial institution under ... the CRS, an account that is a pre-existing entity account with an account balance or value that does not exceed US$250,000 as of 31st December 2015, ...

• (ba) in relation to a reporting financial institution under the CRS, an account meeting the description at Section III(A) of the CRS, and

• (c) in relation to a reporting financial institution under the FATCA agreement, an account meeting the description at paragraph II.A, III.A or IV.A of Annex I of the agreement.

• (2) But—

• (a) in relation to a reporting financial institution under ... the CRS, an account listed as an excluded account in Schedule 2 is not a reportable account,

• (b) in relation to a reporting financial institution under the FATCA agreement, an account is not a reportable account if—

• (i) the account holder is deceased or is a personal representative (within the meaning of section 989 of ITA 2007),

• (ii) the account is held to comply with an order or judgment made or given in legal proceedings, or

• (iii) the funds held in the account are held solely as security for the performance of a party's obligation under a contract for the disposal of an estate or interest in land or of tangible moveable property, and

• (c) in relation to a reporting financial institution—

• (i) for the purposes of ... the CRS, a dormant account (other than an annuity contract) with a balance that does not exceed US$1,000, or

• (ii) an account within paragraph (1)(b), (ba) or (c),

is not a reportable account for a calendar year if there is an election by the institution which has effect for that year to treat all such accounts, or a clearly identified group of such accounts, as not being reportable accounts.

• (3) An election under paragraph (2)(c) must be made for each calendar year for which the election is to have effect in the return required by regulation 6 for that year.

• (4) The reporting financial institution must apply the account balance aggregation and currency rules in the relevant agreement for the purposes of determining whether an account maintained by the institution is within paragraph (1)(b) or (c).

• (5) The account balance aggregation and currency rules are—

• (a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (b) in Section VII.C of the CRS, and

• (c) in paragraph VI.C of Annex I to the FATCA agreement.

• (6) In applying the account balance aggregation and currency rules for the purposes of a relevant agreement and these Regulations, an account balance that has a negative value is treated as having a nil value.

• (7) In determining the balance or value of an account denominated in a currency other than US dollars for the purposes of a relevant agreement and for the purposes of paragraph (1)(b) or (c), the institution must translate the relevant dollar threshold amounts into the other currency by reference to the spot rate of exchange on the date for which the institution is determining the threshold amounts.

• (8) For the purposes of a relevant agreement and these Regulations, an account held by an individual as a partner of a partnership is treated as an entity account and is not treated as an individual account.

• (9) An account is a dormant account if—

• (a) the account holder has not initiated a transaction with regard to the account or any other account held by the account holder with the reporting financial institution in the previous three years,

• (b) the account holder has not communicated with the reporting financial institution regarding the account or any other account held by the account holder with the reporting financial institution in the previous six years,

• (c) the account is treated as a dormant account under the reporting financial institution’s normal operating procedures, and

• (d) in the case of a cash value insurance contract, the reporting financial institution has not communicated with the account holder regarding the account or any other account held by the account holder with the reporting financial institution in the previous six years.

Obligations in relation to financial accounts

Due diligence requirements

3

• (1) A reporting financial institution must establish and maintain arrangements that are designed to identify in respect of a financial account—

• (a) the territory in which an account holder or a controlling person is resident for the purposes of—

• (i) income tax,

• (ii) corporation tax, or

• (iii) any tax imposed by the law of that territory that is of a similar character to either of those taxes, and

• (b) whether it is a reportable account.

• (2) A reporting financial institution must comply with paragraph (1) by applying the due diligence procedures set out in the relevant agreement.

• (2A) A reporting financial institution must keep a record of—

• (a) the steps taken to comply with this regulation, and

• (b) the information collected in the course of identifying the matters referred to in paragraph (1).

• (2B) A reporting financial institution must keep the records required by paragraph (2A) for a period of—

• (a) in respect of an account identified as a reportable account, five years beginning with the end of the year in which the account is last included in a return made under regulation 6(1), or

• (b) in respect of an account which is not a reportable account, five years beginning with the end of the last year in which the reporting financial institution relied upon the due diligence procedures to treat the account as not being a reportable account.

• (3) The due diligence procedures are—

• (a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (b) in relation to a reporting financial institution under the CRS, set out in Sections II to VII of the CRS and the alternative procedure provided in the optional provision in paragraph 13 of the commentary to Section VII of the CRS,

• (c) in relation to a reporting financial institution under the FATCA agreement, set out in Annex I to that agreement.

• (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (4A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (4B) Where a provision of the CRS does not specify a deadline for the requirements of that provision to be satisfied that deadline is—

• (a) in ... Section VIII(C)(10) (new account) ..., 1 January 2016,

• (b) in Section VIII B(9)(d) (exempt collective investment vehicle), 1 January 2018, ...

• (ba) in Section VIII(B)(8)(b) (qualified credit card issuer) and Section VIII(C)(17)(f)(ii) (excluded accounts), 1 January of the year following the calendar year in which the reporting financial institution implemented the policies and procedures required by those provisions, and

• (c) in all other cases, 31 December 2015.

• (5) In applying the due diligence procedures, accounts within regulation 2(1)(b), (ba) and (c) in respect of which no election under regulation 2(2)(c) has been made are treated as new accounts or pre-existing accounts as the case may be.

Modification of due diligence requirements: the DAC and the CRS

4

A reporting financial institution under ... the CRS may—

• (a) apply the due diligence procedures for new accounts to pre-existing accounts, and

• (b) apply the due diligence procedures for high value accounts to low value accounts.

Modifications of due diligence requirements: FATCA agreement

5

• (1) A reporting financial institution under the FATCA agreement may modify the due diligence requirements as follows.

• (2) In the case of an account within paragraph II.B or II.C of Annex I to the FATCA agreement, the due diligence requirements do not include the requirement to carry out the electronic search described in paragraph II.B (1) of that Annex if—

• (a) the institution has established that the account holder is a specified U.S. person from documentary evidence mentioned in paragraph VI.D of Annex I of the agreement, and

• (b) it has done so in order to meet its obligations under a Qualifying Intermediary agreement as mentioned in that paragraph.

• (3) In the case of an account with paragraph II.D or II.E of Annex I to the FATCA agreement, the due diligence requirements do not include the requirement to carry out the electronic searches described in paragraph II.B (1) or II.D (1) of that Annex or the requirement to carry out the paper record search described in paragraph II.D (2) of that Annex if—

• (a) the institution has established the account holder is a specified U.S. person from documentary evidence mentioned in paragraph VI.D of that Annex, and

• (b) it has done so in order to meet its obligations under a Qualifying Intermediary agreement as mentioned in that paragraph.

• (4) The reporting financial institution may rely on evidence that a person is a specified U.S. person obtained in relation to another financial account if the due diligence procedures in the relevant U.S. Treasury Regulations would allow such reliance.

• (5) For the purposes of this regulation references to the documentary evidence set out in paragraph VI.D of Annex I of the FATCA agreement are to be treated as if the words “other than a Form W-8 or W-9” were omitted.

Reporting obligation

6

• (1) A reporting financial institution must, in respect of the first reporting year and every following calendar year, make a return setting out the information required to be reported under the relevant agreement in relation to—

• (a) each reportable account that is maintained by the institution at any time during the calendar year in question, and

• (b) each pre-existing account identified as a reportable account by the institution at any time during the calendar year in question.

• (2) The first reporting year is—

• (a) the calendar year 2014 in relation to an account identified as a reportable account for the purposes of the FATCA agreement,

• (b) the calendar year 2016 in relation to an account identified as a reportable account for the purposes of ... the CRS.

• (3) The information required to be reported is—

• (a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (b) in relation to an account identified as a reportable account for the purposes of the CRS, set out in Section I of the CRS (ignoring paragraph F of Section I),

• (c) in relation to an account identified as a reportable account for the purposes of the FATCA agreement, set out in Article 2(2) of that agreement.

• (4) The return must be submitted electronically in accordance with regulation 7 on or before 31stMay of the year following the calendar year to which the return relates.

• (5) For the purposes of the information required to be reported under the relevant agreement—

• (a) interest includes any amount that is chargeable as interest under Part 4 of ITTOIA 2005 ,

• (b) references to the balance or value of an account include a nil balance or value, and

• (c) references to paying an amount include crediting an amount.

Electronic return system

7

• (1) The return must be made electronically using an electronic return system.

• (2) The form and manner of an electronic return system is specified in specific or general directions given by the Commissioners for Her Majesty's Revenue and Customs.

• (3) A return which is made otherwise than in accordance with paragraphs (1) and (2) is treated as not having been made.

• (4) An electronic return system must incorporate an electronic validation process.

• (5) Unless the contrary is proved—

• (a) the use of an electronic return system is presumed to have resulted in the making of the return only if this has been successfully recorded as such by the relevant electronic validation process,

• (b) the time of making the return is presumed to be the time recorded as such by the relevant electronic validation process, and

• (c) the person delivering the return is presumed to be the person identified as such by any relevant feature of the electronic return system.

• (6) A return made behalf of a reporting financial institution is taken to have been made by that institution, unless the institution proves that the return was made without the institution's authority.

Modifications of reporting requirements: FATCA

8

• (1) In relation to an account identified as a reportable account for the purposes of the FATCA agreement, the information required to be reported is modified as follows.

• (2) In the case of all reportable accounts for the calendar year 2014, the information required to be reported is provided in Article 3(3)(a)(1) of the FATCA agreement.

• (3) In the case of custodial accounts for the calendar year 2015, the information required to be reported is provided in Article 3(3)(a)(2) of the FATCA agreement.

• (4) In the case of pre-existing accounts—

• (a) for calendar years before 2017—

• (i) there is no requirement to include a U.S. federal taxpayer identifying number if the reporting financial institution does not hold that number, but

• (ii) if the account holder is an individual whose date of birth the institution does hold, the institution must include the account holder's date of birth instead, and

• (b) for the calendar year 2017 and subsequent years, if a reporting financial institution does not hold a U.S. federal taxpayer identifying number that it is required to report, the institution must obtain that number from the account holder.

Additional due diligence and reporting obligations in relation to payments to a non-participating financial institution: FATCA

9

• (1) In relation to a reporting financial institution under the FATCA agreement, the due diligence requirements and the information required to be reported are modified as follows in relation to payments to a non-participating financial institution.

• (2) A reporting financial institution must establish and maintain arrangements that are designed to identify payments made by the institution to a non-participating financial institution in the calendar year 2015 or 2016,

• (3) “Payment” here does not include consideration given by the reporting financial institution for the provision of goods or services to it.

• (4) A reporting financial institution must apply the due diligence procedures set out in paragraph IV.D (3) of Annex I of the FATCA agreement to identify whether a financial institution is a non-participating financial institution.

• (5) In respect of any case in the calendar years 2015 and 2016 when a reporting financial institution is within the terms of sub-paragraph 1(e) of Article 4 of the FATCA agreement, the institution must make a disclosure of information in accordance with the requirements of that sub-paragraph.

• (6) A reporting financial institution must in respect of each of the calendar years 2015 and 2016 prepare a return setting out the information set out in Article 4(1)(b) of the FATCA agreement.

• (7) The return must be submitted electronically in accordance with regulation 7 on or before 31stMay of the year following the calendar year to which the return relates.

• (8) For the purposes of this regulation, “non-participating financial institution” includes anyone who is treated as a non-participating financial institution as a result of sub-paragraph 5(a) of Article 4 of the FATCA agreement.

Notification to individual reportable persons

10

• (1) A reporting financial institution must notify each individual reportable person or individual specified U.S. person that information relating to that person which is required to be reported under regulation 6 will be reported to HMRC and may be transferred to the government of another territory in accordance with a relevant agreement.

• (2) The notification must be made by 31st January in the calendar year following the first year in which the account held by the individual is a reportable account maintained by the reporting financial institution.

Non-resident reporting financial institution’s UK representative

11

• (1) If a reporting financial institution is not resident in the United Kingdom, the obligations of the institution under these Regulations are to be treated as if they were also the obligations of any UK representative of the institution.

• (2) “UK representative” has the same meaning as it has in—

• (a) Chapter 6 of Part 22 of CTA 2010, in relation to a reporting financial institution that is within the charge to corporation tax, and

• (b) Chapter 2C of Part 14 of ITA 2007, in relation to any other reporting financial institution.

• (3) For the purposes of this regulation—

• (a) a reporting financial institution which is a partnership is resident in the United Kingdom if the control and management of the business of the partnership as a reporting financial institution takes place there, and

• (b) a reporting financial institution which is not a partnership is resident in the United Kingdom if it is resident in the United Kingdom for corporation tax or income tax purposes.

Use of service providers

12

A reporting financial institution may use a service provider to undertake the due diligence requirements under regulations 3 to 5 and the reporting obligations under regulations 6 and 9, but in such cases those obligations continue to be the obligations of the institution.

Penalties for breach of obligations

Penalties for failure to comply with Regulations

13

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Daily default penalty

14

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Penalties for inaccurate information

15

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FATCA agreement penalty: non-participating financial institutions

16

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Matters to be disregarded in relation to liability to penalties

17

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Assessment of penalties

18

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Right to appeal against penalty

19

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Procedure on appeal against penalty

20

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Increased daily default penalty

21

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Enforcement of penalties

22

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Supplementary

Anti-avoidance

23

If—

• (a) a ... person enters into any arrangements, and

• (b) the main purpose, or one of the main purposes, of ... entering into the arrangements is to avoid any obligation under these Regulations,

these Regulations are to have effect as if the arrangements had not been entered into.

Definitions

24

• (1) In these Regulations—

• “the Commissioners” means the Commissioners for Her Majesty's Revenue and Customs,

• “specified non-reporting financial institution” means a non-reporting financial institution which is a trust within the meaning of Section VIII(B)(1)(e) of the CRS or paragraph II(D) of Annex II to the FATCA agreement,

• “the tribunal” means the First-tier Tribunal or, where determined by or under Tribunal Procedure Rules, the Upper Tribunal,

• “US Treasury Regulations” mean the US Regulations Relating to Information Reporting by Foreign Financial Institutions and Other Foreign Entities .

• (2) The following table lists the places where expressions that apply for the purposes of these Regulations are defined or otherwise explained—

Expression	Regulations	. . .	The CRS	The FATCA agreement
account holder		. . .	Section VIII(E)(1) of the CRS	Article 1(1)(ee)
annuity contract		. . .	Section VIII(C)(6) of the CRS
CRS	regulation 1(3)(aa)
cash value insurance contract		. . .	Section VIII(C)(7) of the CRS
the Commissioners	regulation 24(1)
controlling person		. . .	Section VIII(D)(6) of the CRS	Article 1(1)(mm)
custodial account		. . .	Section VIII(C)(3) of the CRS	Article 1(1)(u)
. . .	. . .
entity		. . .	Section VIII(E)(3) of the CRS	Article 1(1)(hh)
excluded accounts	Schedule 2	. . .	Section VIII(C)(17) of the CRS
the FATCA agreement	regulation 1(3)(c)
financial account		. . .	Section VIII(C) of the CRS	Article 1(1)(s)
financial institution	regulation 1(5A)	. . .	Section VIII(A)(3) of the CRS
high value account		. . .	Section VIII(C)(15) of the CRS	Section II(D) of Annex I
NFE		. . .	Section VIII(D)(7) of the CRS
investment entity	regulation 1(5A)	. . .	Section VIII(A)(6) of the CRS
subject to paragraph (3) new account		. . .	Section VIII(C)(10) of the CRS
non-participating financial institution				Article 1(1)(r)
non-reporting financial institution		. . .	Section VIII(B)(1) of the CRS
participating jurisdiction	regulation 1(7)(d)	. . .	Section VIII(D)(5) of the CRS
subject to regulation 3(4A)(a) and paragraph (3) pre-existing account	. . .	. . .	subject to paragraph (3), the replacement for Section VIII(C)(9) of the CRS in paragraph 82 of the commentary to Section VIII of the CRS	Article 1(1)(aa)
pre-existing entity account		. . .	Section VIII(C)(13) of the CRS	Section IV of Annex I
qualified non-profit entity	regulation 1(7)(b)		Section VIII(B)(10) of the CRS in paragraph 36sexies of the commentary to Section VIII of the CRS
related entity	. . .	. . .	the replacement for Section VIII(E)(4) of the CRS in paragraph 82 of the commentary to Section VIII of the CRS
reportable account	regulation 2	. . .	Section VIII(D)(1) of the CRS	Article 1(1)(bb)
reportable jurisdiction	regulation 1(7)(c)		Section VIII(D)(4) of the CRS
reporting financial institution		. . .	Section VIII(A)(1) of the CRS	Article 1(1)(n)
reportable person		. . .	Section VIII(D)(2) of the CRS
relevant agreement	Regulation 1(5)
self-certification provider	regulation 12GA
specified non-reporting financial institution	regulation 24(1)
. . .	. . .
. . .	. . .
specified U.S. person				Article 1(1)(gg)
the tribunal	regulation 24(1)
UK representative	regulation 11(2)
U.S. reportable account				Article 1(1)(dd) and paragraph I.B of Annex I
U.S. Treasury Regulations	regulation 24(1)

• (3) In respect of the accounts listed in paragraph (4)—

• (a) “new account” means a financial account maintained by a reporting financial institution opened on or after 13th May 2020;

• (b) “pre-existing account” means—

• (i) a financial account maintained by a reporting financial institution as of 12th May 2020, or

• (ii) a financial account within the replacement for Section VIII(C)(9) of the CRS in paragraph 82 of the commentary to Section VIII of the CRS, but in the application of that provision the references to “subparagraph C(9)(a)” are to be read as references to paragraph (i) of this sub-paragraph.

• (4) The accounts are—

• (a) non-registered pension arrangements where the annual contributions are limited to £50,000 and funds contributed cannot be accessed before the age of 55 except in circumstances of serious ill health;

• (b) Premium Bonds issued by the UK National Savings and Investments;

• (c) Fixed Interest Savings Certificates issued by the UK National Savings and Investments; and

• (d) Index Linked Savings Certificates issued by the UK National Savings and Investments.

Revocation

25

The International Tax Compliance (United States of America) Regulations 2014 are revoked.

SCHEDULE 1 — Participating jurisdictions

The participating jurisdictions for the purposes of the CRS are set out in the following list.

Albania
Andorra
Anguilla
Antigua and Barbuda
Argentina
Aruba
Austria
Australia
The Bahamas
Barbados
Belgium
Belize
Bermuda
Brazil
British Virgin Islands
Brunei Darussalam
Bulgaria
Canada
Cayman Islands
Chile
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Estonia
Faroe Islands
Finland
France
Germany
Gibraltar
Greece
Greenland
Grenada
Guernsey
Hong Kong (China)
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Japan
Jersey
Korea
Latvia
Liechtenstein
Lithuania
Luxembourg
Macao (China)
Malaysia
Malta
Marshall Islands
Mauritius
Mexico
Monaco
Montserrat
Netherlands
New Zealand
Niue
Norway
Poland
Portugal
Qatar
Romania
Russian Federation
Saint Kitts and Nevis
Saint Lucia
Saint Vincent and the Grenadines
Samoa
San Marino
Saudi Arabia
Seychelles
Singapore
Sint Maarten
Slovak Republic
Slovenia
South Africa
Spain
Sweden
Switzerland
Trinidad and Tobago
Turkey
Turks and Caicos Islands
United Arab Emirates
Uruguay

SCHEDULE 2 — Excluded accounts

For the purposes of the DAC and the CRS the following are excluded accounts.

Certain Retirement Accounts or Products

1

Pension schemes registered with HMRC under Part 4 of FA 2004 .

2

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3

Immediate needs annuities within section 725 ITTOIA 2005 .

Certain Tax-favoured Accounts and Products

4

An account within the meaning of the Individual Savings Account Regulations 1998 .

5

A child trust fund within the meaning of the Child Trust Funds Act 2004 .

6

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7

Children's Bonds issued by the UK National Savings and Investments.

8

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9

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10

Tax Exempt Savings Plans issued by a friendly society within the meaning of the Friendly Societies Act 1992 .

11

A share incentive plan approved by HMRC under Schedule 2 to ITEPA 2003 .

12

A SAYE option scheme approved by HMRC under Schedule 3 to ITEPA 2003.

13

A CSOP scheme approved by HMRC under Schedule 4 to ITEPA 2003.

14

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15

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Signed

Alun Cairns — David Evennett — Two of the Lords Commissioners of Her Majesty's Treasury — 2015-03-24

Explanatory note

(This note is not part of the Regulations)

Footnotes

[^f00001]: 2002 c. 23.

[^f00002]: 2013 c. 29.

[^f00003]: OJ No L 64, 11.3.2011, p1, relevantly amended by Council Directive 2014/107/EU, OJ No L 359, 16.12.2014, p1.

[^f00004]: The standard for automatic exchange of financial account information developed by the Organisation for Economic Co-Operation and Development (“the OECD”) is available on the OECD website at http://www.oecd.org/ctp/exchange-of-tax-information/standard-for-automatic-exchange-of-financial-information-in-tax-matters.htm. The OECD Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information is available on OECD website at http://www.oecd.org/ctp/exchange-of-tax-information/multilateral-competent-authority-agreement.pdf.

[^f00005]: That agreement, as signed on that date, is contained in a Command Paper published by the Stationery Office Ltd with the title “Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA” (Cm 8445, 2012); the Command Paper is available on the Official Documents website at http://www.official-documents.gov.uk/document/cm84/8445/8445.pdf.

[^f00006]: 2005 c. 5.

[^f00007]: 1970 c. 9. The Taxes Management Act 1970 was relevantly amended by sections 45(1) and 67(2) of the Finance (No. 2) Act 1975 (c. 45); section 68 of the Finance Act 1982 (c. 39); section 156(2) and (4) of the Finance Act 1989 (c. 26); section 199 of and paragraphs 18(1) and (2) of Schedule 19 to the Finance Act 1994 (c. 9); paragraph 28 of Schedule 19 to the Finance Act 1998 (c. 36); section 88 of and paragraph 31 of Schedule 29 to the Finance Act 2001 (c. 9); paragraph 21 of Schedule 1 to the Constitutional Reform Act 2005 (c. 4); paragraph 257(a) and (b) of Schedule 1 to and Part 1 of Schedule 3 to the Income Tax Act 2007 (c. 3); section 119(12)(a) of the Finance Act 2008 (c. 9); paragraph 31 of Schedule 7 to the Taxation (International and Other Provisions) Act 2010 (c. 8); S.I. 1994/1813 and 2009/56.

[^f00008]: The Regulations can be found on the US Department of the Treasury website at http://www.treasury.gov/resource-center/tax-policy/treaties/Pages/FATCA.aspx.

[^f00009]: S.I. 2014/1506.

[^f00010]: 2004 c. 12.

[^f00011]: 2005 c. 5.

[^f00012]: S.I. 1998/1870, relevantly amended by S.I. 2002/1974, 2007/2119, 2008/704, 2009/1994, 2010/2957, 2011/782 and 2011/1780.

[^f00013]: 2004 c. 6.

[^f00014]: 1992 c. 40.

[^f00015]: 2003 c. 1.

[^f00016]: 2007 c. 3.

Introductory

Citation, commencement, effect and interpretation

Meaning of “reportable account”

Obligations in relation to financial accounts

Due diligence requirements

Modification of due diligence requirements: ... the CRS

Modifications of due diligence requirements: FATCA agreement

Reporting obligation

Electronic return system

Modifications of reporting requirements: FATCA

Additional due diligence and reporting obligations in relation to payments to a non-participating financial institution: FATCA

Notification to individual reportable persons

Non-resident reporting financial institution's UK representative

Use of service providers

Penalties for breach of obligations

Penalties for failure to comply with Regulations

Daily default penalty

Penalties for inaccurate information

FATCA agreement penalty: non-participating financial institutions

Matters to be disregarded in relation to liability to penalties

Assessment of penalties

Right to appeal against penalty

Procedure on appeal against penalty

Increased daily default penalty

Enforcement of penalties

Supplementary

Anti-avoidance

Definitions

Revocation

The participating jurisdictions for the purposes of the CRS are set out in the following list.

Albania
Andorra
Anguilla
Antigua and Barbuda
Argentina
Aruba
Austria
Australia
The Bahamas
Barbados
Belgium
Belize
Bermuda
Brazil
British Virgin Islands
Brunei Darussalam
Bulgaria
Canada
Cayman Islands
Chile
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Estonia
Faroe Islands
Finland
France
Germany
Ghana
Gibraltar
Greece
Greenland
Grenada
Guernsey
Hong Kong (China)
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Japan
Jersey
Korea
Latvia
Liechtenstein
Lithuania
Luxembourg
Macao (China)
Malaysia
Malta
Marshall Islands
Mauritius
Mexico
Monaco
Montserrat
Netherlands
New Zealand
Niue
Norway
Poland
Portugal
Qatar
Romania
Russian Federation
Saint Kitts and Nevis
Saint Lucia
Saint Vincent and the Grenadines
Samoa
San Marino
Saudi Arabia
Seychelles
Singapore
Sint Maarten
Slovak Republic
Slovenia
South Africa
Spain
Sweden
Switzerland
Trinidad and Tobago
Turkey
Turks and Caicos Islands
United Arab Emirates
Uruguay

For the purposes of the DAC and the CRS the following are excluded accounts.

Certain Retirement Accounts or Products

Certain Tax-favoured Accounts and Products

Editorial notes

[^c22477251]: 2002 c. 23.

[^c22477261]: 2013 c. 29.

[^c22477301]: 2005 c. 5.

[^c22477321]: The Regulations can be found on the US Department of the Treasury website at http://www.treasury.gov/resource-center/tax-policy/treaties/Pages/FATCA.aspx.

[^c22477331]: S.I. 2014/1506.

[^c22477341]: 2004 c. 12.

[^c22477351]: 2005 c. 5.

[^c22477361]: S.I. 1998/1870, relevantly amended by S.I. 2002/1974, 2007/2119, 2008/704, 2009/1994, 2010/2957, 2011/782 and 2011/1780.

[^c22477371]: 2004 c. 6.

[^c22477381]: 1992 c. 40.

[^c22477391]: 2003 c. 1.

[^key-3e6d82c964012522a32dfbc9e0d17784]: Reg. 1(5A) inserted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(2)

[^key-048513432a58616cd2ad07a67a081084]: Reg. 2(9) inserted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(4)

[^key-3463e0bb842bd358e51b99b7e995c99e]: Reg. 2(2)(c) substituted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(3)

[^key-cfc35d0cda464a7692e4d7269cd3db25]: Words in reg. 24(2) substituted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(5)(a)

[^key-5f1d127d0deeaed21bad2f4e366e9867]: Words in reg. 24(2) inserted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(5)(b)

[^key-9ea3b4ed22e58883ec2431a6bfefa559]: Words in reg. 24(2) substituted (20.11.2015) by The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(5)(c)

[^key-089c0e34f01c83616d404bbaf8d76d5f]: Sch. 2 paras. 14, 15 omitted (20.11.2015) by virtue of The International Tax Compliance (Amendment) Regulations 2015 (S.I. 2015/1839), regs. 1, 2(7)

[^key-ec4dc36511ff959e7afd659714c3fbda]: Words in reg. 24(2) inserted (30.9.2016) by The International Tax Compliance (Client Notification) Regulations 2016 (S.I. 2016/899), regs. 1, 6(a)

[^key-d5dde5aae21ee911b069f96acdf2979b]: Words in reg. 24(2) inserted (30.9.2016) by The International Tax Compliance (Client Notification) Regulations 2016 (S.I. 2016/899), regs. 1, 6(b)

[^key-bd99a3eee3698add06a856c0ce92990c]: Sch. 1 omitted (17.5.2017) by virtue of The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 20

[^key-d862c93b859f8bec8f8842bfe98df8d6]: Reg. 12G inserted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 8

[^key-8ee7f55c18f902b90e25f069857f9495]: Reg. 12H inserted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 9(1)

[^key-4faa260a6dd7209681144f3e22e01cf2]: Word in reg. 2(1)(b) omitted (17.5.2017) by virtue of The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 4(1)(a)

[^key-3ad6640b19ffcb7917ad9c83cce6df33]: Reg. 2(1)(ba) inserted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 4(1)(b)

[^key-94745cb208db5eeaead9ab0dcb584516]: Words in reg. 2(2)(c)(ii) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 4(2)

[^key-04f244043e7c562bd6adf37fc0d6f9b6]: Reg. 3(1)-(2B) substituted for reg. 3(1)(2) (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 5(1)

[^key-1f9a1dc52fc27c0370160773b2cddfc4]: Reg. 3(4)-(4B) substituted for reg. 3(4) (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 5(3)

[^key-5667a869ef134b02be386ebae052e1f5]: Reg. 3(3)(b) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 5(2)

[^key-8ea9dd505b6d87920fa10c6e301566b1]: Words in reg. 3(5) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 5(4)

[^key-ecae7fc1449217ea4f14b3726c427abf]: Reg. 6(1) substituted (with application in accordance with reg. 1(2) of the amending S.I.) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 6(1)

[^key-c1f53de5cc90909ae31fd84d237e52b2]: Reg. 6(3)(b) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 6(2)

[^key-f8256ee199b2e98084d62688ad929f64]: Words in reg. 23 substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 18(a)

[^key-194d812bc6eba5bfb03f8adb4539b14f]: Words in reg. 24(2) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 19(a)

[^key-de007a04711a5f19280c58c69c3cda5b]: Words in reg. 24(2) inserted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 19(b)

[^key-87da8e30a1b82291f1c581292754933c]: Words in reg. 24(2) substituted (17.5.2017) by The International Tax Compliance (Amendment) Regulations 2017 (S.I. 2017/598), regs. 1(1), 19(c)

[^key-5d39265de56afe079b1ce0df290823c4]: Reg. 24(3)(4) inserted (13.5.2020) by The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(4)(b) (with reg. 3)

[^key-d448045fb2f8a35a2e322225d0946048]: Words in reg. 24(2) inserted (13.5.2020) by The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(4)(a)(i) (with reg. 3)

[^key-b7e0d5302fba341b97cc627631d38934]: Words in reg. 24(2) inserted (13.5.2020) by The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(4)(a)(ii) (with reg. 3)

[^key-c562ce8649aeda751d305a87f9982244]: Sch. 2 para. 2 omitted (13.5.2020) by virtue of The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(5) (with reg. 3)

[^key-a18e62b2385d27ef02323ac6774e23c7]: Sch. 2 para. 6 omitted (13.5.2020) by virtue of The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(5) (with reg. 3)

[^key-a153d3d32573594279f068237cd734ec]: Sch. 2 para. 8 omitted (13.5.2020) by virtue of The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(5) (with reg. 3)

[^key-927438a6a7a7d7e473807b8890fb37c6]: Sch. 2 para. 9 omitted (13.5.2020) by virtue of The International Tax Compliance (Amendment) Regulations 2020 (S.I. 2020/438), regs. 1, 2(5) (with reg. 3)

[^key-23a928b4b1ae851202d3d889442a9f3e]: Words in reg. 6(2)(b) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(6)(a)

[^key-cfd15a850a6e4eb1e89c664263a1341c]: Reg. 6(3)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(6)(b)

[^key-b0afa573753e912bebcf43d51194b163]: Words in reg. 24(2) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(a)

[^key-1f592658fa232de6d30048bce2c14dc2]: Words in reg. 24(2) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(b)

[^key-5d77b9f11cfb22699379e637e50f9f0c]: Words in reg. 24(2) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(c)

[^key-635b845c29d1524aa9a2c4288e7d80e8]: Words in reg. 24(2) substituted (31.12.2020) by The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(d)(i)

[^key-ac601a515286b79214b53121fcde65b1]: Words in reg. 24(2) substituted (31.12.2020) by The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(d)(ii)

[^key-743402d41831c5781df0bae7337eed17]: Words in reg. 24(3)(b)(ii) substituted (31.12.2020) by The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(8)(e)

[^key-d5c064f6ef9d64866d8226b37a3ddbe6]: Reg. 1(3)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(2)(a)(i)

[^key-3218e4719c6f14de90d17b9e090a1444]: Words in reg. 1(4)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(2)(c)

[^key-3820921e0bac58940eca17f4585a823f]: Words in reg. 2(1)(b) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(3)(a)

[^key-716a6c45641d9c3be4fe4f7a0944158b]: Words in reg. 2(2)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(3)(a)

[^key-7948e56f160ec2c6ba5f2e25be5dfe69]: Words in reg. 2(2)(c) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(3)(a)

[^key-d371845b6c83bd71a2e00cef62eb9139]: Reg. 2(5)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(3)(b)

[^key-1feb01f09622ec359afcf2707604cb9a]: Words in reg. 3(3)(b) inserted (31.12.2020) by The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(4)(b)

[^key-0290e592dbb957fe9027e26243757c4d]: Reg. 3(4) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(4)(c)

[^key-989d5c8a4a7f9ec488adc6472a9c8a19]: Reg. 3(4A) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(4)(c)

[^key-9d8f6755a4af5d51f657dac906908dcd]: Words in reg. 3(4B) substituted (31.12.2020) by The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(4)(d)

[^key-0a0b8a3083e5ee68ff1566ba4d35ee97]: Reg. 3(3)(a) omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(4)(a)

[^key-fcfeecf2d72ccfbb4f7592670e083ece]: Words in reg. 4 heading omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(5)

[^key-e21f8a666291d877d7b0b4489249a27f]: Words in reg. 4 omitted (31.12.2020) by virtue of The International Tax Compliance (Amendment) (No. 2) (EU Exit) Regulations 2020 (S.I. 2020/1300), regs. 1, 2(5)

[^key-42ed7fb2022853638a9d0c4759fc08f8]: Reg. 1(7) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(d) (with reg. 1(2))

[^key-7dfddfed823a4bd8ab43f9ec897a3f9b]: Reg. 1(3)(aa) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(a)(i) (with reg. 1(2))

[^key-fdd72785845957893250e601332bed5a]: Reg. 1(3)(b) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(a)(ii) (with reg. 1(2))

[^key-995a7c9e0c13c888c23b99f28b9cdb6e]: Reg. 1(3)(c) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(a)(iii) (with reg. 1(2))

[^key-70fdf2dc8a63a47a87707fbf9f48023c]: Reg. 1(3A) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(b) (with reg. 1(2))

[^key-8998beea161f3f9e406422cc038ac9c1]: Words in reg. 1(6) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 3(c)

[^key-04444fc93883b4b557a41070b7694d8f]: Word in reg. 3(4B) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 4(b)

[^key-f8ee2ff5d1547e7655aee442ef134455]: Reg. 3(4B)(ba) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 4(b)

[^key-d2ac23dc2cdcc768db8cb8f6ac46882b]: Words in reg. 3(4B)(a) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 4(a)

[^key-8c5eb86f524a311c96e67d78b78d1e8d]: Regs. 12A-12F omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 7(2)

[^key-e6a798d6f492d3b18caeccd2b65a2ab2]: Reg. 12A cross-heading omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 7(1)

[^key-e2f38a7a392fcbbad1b8ec06822056b6]: Words in reg. 12G(1) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 8

[^key-7193d6703f7ddba52a8fa7c215d47f27]: Words in reg. 12H(1) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 10(a)

[^key-0f9d83bf779b7836e845a56e8c92e174]: Words in reg. 12H(1)(a) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 10(b)

[^key-22e92c3d003ccee40dd89b0c2e470d4e]: Reg. 12H(3)(a) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 10(c)

[^key-5899d41e9642edf3a95f13d2ea9dadad]: Reg. 12H(3)(b) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 10(c)

[^key-2758f9c62ea90391253772fce22d8671]: Words in reg. 23(a) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 13(a)

[^key-0971855075fc4768f9918e4c495200a6]: Words in reg. 23(b) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 13(b)

[^key-f931bbb2580c09f48b2604002beeb97c]: Words in reg. 24(2) omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(i)

[^key-646895384b1129df8793b48cb2d8168e]: Words in reg. 24(2) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(ii) (with reg. 1(2))

[^key-958a7b1a85be3817ecc5cdc2010b3539]: Words in reg. 24(2) substituted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(iii) (with reg. 1(2))

[^key-42721df2e0ea0e7aeab06212a7ef5920]: Words in reg. 24(2) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(iv) (with reg. 1(2))

[^key-ca1fe04e04e20c0eca51c143b076d2cc]: Words in reg. 24(2) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(v) (with reg. 1(2))

[^key-e07f1ff062ac613deebed9765b6c8732]: Words in reg. 24(2) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(b)(vi)

[^key-26ab6f906adb8885e3d29fefa8872ac1]: Words in reg. 24(1) inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 14(a)

[^key-fd08cc088875ad9e65106f37c828f79b]: Reg. 7A inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 5 (with reg. 1(2))

[^key-f07ba3ec61ff21d58c18c68688466cc7]: Reg. 10A inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 6

[^key-d37d26d3a9412eb3bec3e523f03e2a2d]: Reg. 12GA inserted (16.7.2025) by The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 9

[^key-4f925c67a08d7a1447c9a01d47401a7e]: Regs. 13-22 omitted (16.7.2025) by virtue of The International Tax Compliance (Amendment) Regulations 2025 (S.I. 2025/740), regs. 1(1), 11