Jurisdiction(s):
United Kingdom

Key definition

FATCA definition

What does FATCA mean? In legal practice, FATCA refers to the client/account due diligence and tax‑information reporting regime requiring UK and Irish financial institutions to identify and report US taxpayers. It originates in the US Foreign Account Tax compliance Act (2010) but, in the UK and Ireland, operates through Model 1 intergovernmental agreements with the US and domestic regulations. Institutions must detect US indicia, obtain self‑certifications, determine whether accounts are “US reportable”, and report annually to HMRC or the Revenue Commissioners for transmission to the IRS. Non‑compliance risks 30% withholding on certain US‑source payments and counterparty restrictions. Most UK registered pension schemes and many...

FATCA, CRS and CARF for UK employee incentive arrangements: investment entity and custodial status, exempt products, financial accounts, due diligence, reporting and documentation

Published by a LexisNexis Tax expert

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 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...

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Ali Kazimi

Hansuke

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....

Web page updated on 21/05/2026

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