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Crown Dependencies and Overseas Territories

The UK’s Agreements with its Crown Dependencies and Overseas Territories (“CDOT”) went live on 1 July 2014.  It seeks to identify UK tax residents who are holding funds in those jurisdictions by extending the FATCA provisions.  It also places obligations on UK Financial Institutions to identify funds that are held by tax residents of Guernsey, Jersey, the Isle of Man and Gibraltar.

The information that is provided will be used by HM Revenue & Customs (“HMRC”) in their fight against tax evasion, providing them with valuable insight into the beneficial owners of complex corporate and trust structures, as well as directly-held bank and fund accounts.

Whilst CDOT is based on FATCA, there are a number of differences that FIs and their customers need to be aware of.

Our experienced team draws on its practical knowledge to help FIs develop governance around its due diligence and reporting obligations. 

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