Ali Kazimi
Ali Kazimi is the managing director at Hansuke. He has over 25 years of financial services industry experience having held successive leadership roles within 'big four' firms and as head of tax at Barclays Global Investors (now BlackRock). Ali is a chartered accountant and a long-standing member of the Chartered Institute for Securities and Investment, International Fiscal Association, and the Association of Corporate Treasurers.
Practice Area
Panel
- Contributing Author
6 Contributions by Ali Kazimi
PRACTICE NOTES
AEoI for UK pension schemes: FATCA/CRS status of registered and unregistered arrangements, excluded accounts, due diligence and reporting, and 2025–2026 updates (CRS changes and CARF)
STOP PRESS/FORTHCOMING CHANGES :
The UK intends to bring the OECD’s Cryptoasset Reporting Framework (CARF) into domestic legislation, taking effect from 1 January 2026. The implementing instrument is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), formally presented to the House of Commons on 25 June 2025. On the same date, HMRC released official tax impact and information notes (TIIN) for the measure. HMRC has additionally also issued public guidance on reporting under the CARF. The government has likewise introduced new legislation revising the existing domestic law implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878), and, separately, the modifying statutory measure is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). These amendments enact the OECD’s important 2023 updates to the CRS and add further technical adjustments ‘to make the UK’s implementation of the rules more effective’ ( Explanatory Memorandum, para 5.5 ). The key changes are to bring e-money institutions within the scope of the reporting requirements, to mandate additional information reporting and to...
Tax
PRACTICE NOTES
Common Reporting Standard (CRS) in the UK: scope, due diligence, reporting and legal framework; differences from FATCA; 2025 regulatory changes and CARF commencement in 2026
STOP PRESS/FORTHCOMING CHANGES :
The UK intends to transpose the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law from 1 January 2026. The enabling instrument is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which was presented to the House of Commons on 25 June 2025. On that date, HMRC released tax impact and information notes (TIIN) on the measure. HMRC has also issued guidance covering reporting under CARF. In parallel, the government has brought forward legislation revising the domestic rules that give effect to the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The core legislation remains the International Tax Compliance Regulations 2015 (SI 2015/878), with amendments made by the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). These changes implement the OECD’s 2023 updates to the CRS and make further adjustments ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5)...
Tax
PRACTICE NOTES
FATCA, CRS and CARF for UK employee incentive arrangements: investment entity and custodial status, exempt products, financial accounts, due diligence, reporting and documentation
STOP PRESS/FORTHCOMING CHANGES :
The UK intends to bring the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law from 1 January 2026. Implementation will be through the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which were laid before the House of Commons on 25 June 2025. On the same day, HMRC issued tax impact and information notes (TIIN) for the measure. HMRC has also published guidance on reporting under the CARF. The government has likewise introduced legislation amending the domestic provisions implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878) and the amending instrument is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). The amendments implement the OECD’s 2023 updates to the CRS and introduce other changes ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5). The principal changes are to include e-money institutions within the scope of the reporting requirements, to require additional information reporting and to, where appropriate, therein and thereof duly...
Tax
PRACTICE NOTES
UK FATCA (CDOT) with Crown Dependencies and Overseas Territories: obligations, reciprocity, legal basis, penalties, key dates, alternative reporting regime, and transition to CRS (archived)
ARCHIVED: This archived Practice Note summarises the arrangements made between the UK and its Crown Dependencies and Overseas Territories to exchange information on financial accounts—known as the Crown Dependency/Overseas Territory (CDOT) agreements—and the reporting required under those arrangements for periods up to the end of 2016, before CDOT was superseded by the Common Reporting Standard (CRS). For details on CRS, see Practice Note: Automatic exchange of information—the Common Reporting Standard: a summary.
What are the CDOT agreements?
The UK entered into agreements with its three Crown Dependencies and a number of Overseas Territories to provide details of financial accounts held in those jurisdictions by UK tax residents (or passive investment companies controlled by such individuals):
Crown Dependencies: Guernsey, Jersey, the Isle of Man
Overseas Territories: Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Montserrat, Turks & Caicos Islands
Together, these arrangements are referred to as the CDOT agreements, CDOT, or UK FATCA. The impetus for these measures was the US Foreign Account Tax Compliance Act (FATCA). Each jurisdiction sought to conclude an Intergovernmental Agreement (IGA) to implement FATCA. As such IGAs are treated as international treaties, they required the UK’s consent. Accordingly, it was agreed...
Tax
PRACTICE NOTES
UK funds and AEoI: FATCA, CRS and CARF—scope, due diligence, reporting and documentation for fund structures, collective investment schemes and distributors (2025 amendments; 2026 cryptoasset reporting)
STOP PRESS/FORTHCOMING CHANGES :
The UK intends to transpose the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law from 1 January 2026. This will be delivered via the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), laid before the House of Commons on 25 June 2025. On the same day, HMRC issued tax impact and information notes (TIIN) for the measure, and also released guidance covering CARF reporting.
At the same time, the government has brought forward amendments to the domestic implementation of the OECD’s Common Reporting Standard (CRS) and to the UK’s obligations under the Intergovernmental Agreement with the US for the US Foreign Account Tax Compliance Act (FATCA). The principal framework remains the International Tax Compliance Regulations 2015 (SI 2015/878), with changes introduced by the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). These updates enact the OECD’s 2023 revisions to the CRS and add further modifications ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5)...
Tax
PRACTICE NOTES
UK implementation of FATCA via the UK–US IGA and International Tax Compliance Regulations 2015: classification, exemptions, due diligence, reporting duties and penalties for financial institutions
This Practice Note provides a broad overview of:
the intergovernmental agreement between the UK and the US to enhance international tax compliance and to give effect to FATCA, signed on 12 September 2012 (the UK:US IGA), and
the International Tax Compliance Regulations 2015, SI 2015/878 (the International Tax Compliance Regulations), insofar as they relate to implementing the UK:US IGA
The International Tax Compliance Regulations took effect on 15 April 2015. They supersede and repeal the International Tax Compliance Regulations (United States of America) Regulations 2014, SI 2014/1506, which were in force from 30 June 2014 until 14 April 2015.
The International Tax Compliance Regulations and the UK:US IGA comprise detailed and demanding provisions. This Practice Note is a summary and does not address every facet of the framework. In certain sections, it necessarily adopts a broad-brush treatment, which unavoidably trims back some of the finer detail...
Tax
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