02.02 – Holding Companies and Treasury

There are two categories of a financial institution that are not replicated in the International Tax Compliance (Crown Dependencies and Gibraltar) Regulations 2014. These are:

  • relevant holding company
  • treasury company

The reason for the inclusion of Relevant Holding Company and Treasury Company in the International Tax Compliance (United States of America) Regulations 2013 is to ensure that reporting on payments to Non-Participating Financial Institutions cannot be circumnavigated by using associated entities. This is not relevant for the International Tax Compliance (Crown Dependencies and Gibraltar) Regulations 2014 as there is no requirement to report on payments made to Non-Participating Financial Institutions.

Under the terms of the International Tax Compliance (Crown Dependencies and Gibraltar) Regulations 2014, the type of entity that could fall within the categories of Relevant Holding Company or Treasury Company, but would not necessarily fall within any of the other categories of Financial Institution, would not offer financial accounts. A Financial Institutions that does not offer Financial Accounts will have no due diligence to apply and no accounts to report under the International Tax Compliance (Crown Dependencies and Gibraltar) Regulations 2014.