UK FATCA Update 2016

Financial Institutions will be required to provide the first report under UK FATCA on or before 31 May 2016 in respect of any financial accounts maintained during the calendar year 2014 or 2015.

In this regard, if a Financial Institution did not also notify the Tax Information Authority that it is a Reporting Financial Institution for UK FATCA purposes when it made its notification last year in respect of US FATCA, it will be required to do so by 30 April 2016 via the Cayman Islands AEOI Portal, accessible at www.ditc.gov.ky.  The first report in respect of UK FATCA due on or before 31 May 2016 should include relevant information relating to:

• all new accounts opened after 1 July 2014;
• pre-existing high value individuals’ accounts as the due diligence for such accounts must have been completed by 30 June 2015; and those pre-existing lower value individual accounts and pre-existing entity accounts that have been identified as reportable in 2014 or 2015.

See our last update on FATCA here.