(May 21, 2015)
On May 21, 2015 on the website GOV.UK a guidance titled: “Automatic Exchange of Information: holding companies and treasury companies” was published. The guidance was issued by the HM Revenue & Customs (HMRC) and sets out HMRC’s views relating to the treatment of holding companies and treasury companies for the purposes of the UK’s agreements relating to the automatic exchange of information on financial accounts, the UK/US agreement Foreign Account Tax Compliance Act (FATCA), the UK/Crown Dependencies and Gibraltar agreement, and the Multilateral Competent Authority agreement implementing the Common Reporting Standard, the latter taking effect for EU member states under Council Directive 2011/16/EU.
The guidance also states that it will be incorporated into HMRC’s updated AEOI guidance at a later date.
The guidance is divided into the following paragraphs:
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General position
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Background to removing ‘relevant holding company’ and ‘treasury company’ from definition of UKFI
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Approach to determining appropriate entity status
Click here to be forwarded to the guidance as available on GOV.UK.
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