01.02 – Scope of the agreements between the UK and the Crown Dependencies and Overseas Territories to improve international tax compliance

The UK has signed agreements with the Crown Dependencies (the Isle of Man, Guernsey and Jersey) and seven of the Overseas Territories (Cayman Islands, Gibraltar, Montserrat, Bermuda, the Turks and Caicos Islands, the British Virgin Islands and Anguilla). These agreements are based on the FATCA agreements that each jurisdiction has signed with the US.

The UK will only be introducing regulations to implement the reciprocal versions of these agreements, as these are the only agreements that require any reporting by UK Financial Institutions. The reciprocal agreements are those between the UK and the Isle of Man, Guernsey, Jersey and Gibraltar.

These regulations will apply to UK Financial Institutions in the same way as the regulations to implement the UK’s IGA with the US and will impose obligations on Financial Institutions to identify and report relevant data to HMRC on account holders or controlling persons of Passive NFFEs, who are residents of the Isle of Man, Guernsey, Jersey or Gibraltar.