Automatic Exchange of Information Handbook

John Hiddleston is a Tax Consultant at Azets. He has held senior roles in the tax technical departments of Top 20 accountancy firms – having been Head of Tax Technical at Vantis and, before that, National Director of Tax Technical at Howarth Clark Whitehall (Crowe UK). In a career spanning several decades, John has also done an unusually wide variety of practical tax work, having worked for independent tax consultancies and, even longer ago, as in-house Tax Manager at a multinational corporate.

1 How we got here – A quick look at the recent history of Automatic Exchange
2 The UK and Automatic Exchange today, including the impact of Brexit
3 An overview of FATCA and CRS
4 What is a reporting financial institution under FATCA/CRS? Why is it important?
5 What is a financial account? Why is that important?
6 How are different kinds of entities and persons affected by FATCA/CRS?
7 FATCA/CRS – Advising, assisting, looking after and dealing with clients
8 FATCA/CRS – What might happen to us, if we didn’t comply?
9 FATCA/CRS – Due diligence requirements under the UK’s regulations
10 FATCA/CRS due diligence of individual accounts
11 FATCA/CRS due diligence of entity accounts (including NFEs and NFFEs)
12 Making a report under the UK’s FATCA/CRS regulations
13 EU DAC 6 – the EU Mandatory Disclosure regime
14 EU DAC 6 – Who must report?
15 EU DAC 6 – What must be reported, when and how?
16 EU DAC 6 – Other obligations
17 EU DAC 6 – The hallmarks
18 EU DAC 6 – Penalties for non-compliance
19 Other forms of exchange under EU DAC
20 HMRC’s legal framework for exchange
Appendix I – List of countries with a FATCA agreement with the USA
Appendix II – OECD Common Reporting Standard (‘CRS’) participant countries
Appendix III – Flowchart 1 – Is this a financial institution?
Appendix IV – Flowchart 2 – Is this a UK reporting financial institution?
Appendix V – Flowchart 3 – What FATCA and CRS due diligence must a reporting financial institution carry out?
Appendix VI – Flowchart 4 – FATCA and CRS due diligence in relation to new individual accounts
Appendix VII – Flowchart 5 – FATCA and CRS due diligence for a reporting financial institution in relation to new entity accounts
Appendix VIII – Flowchart 6 – Must a UK reporting financial institution treat this as a CRS or FATCA reportable account?
Appendix IX – Flowchart 7 – Must a DAC 6 return be made?