Hansuke
6 Contributions by Hansuke Experts
PRACTICE NOTES
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
Tax
PRACTICE NOTES
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
Tax
PRACTICE NOTES
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
Tax
PRACTICE NOTES
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
Tax
PRACTICE NOTES
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
Tax
PRACTICE NOTES
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
Tax
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