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HMRC internal manual

International Exchange of Information Manual

Background: CDOT

The Crown Dependencies and Overseas Territories

The Crown Dependencies of Guernsey, the Isle of Man and Jersey and the UK Overseas Territories of Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands, Gibraltar, Montserrat and the Turks & Caicos Islands have all entered into agreements with the UK to automatically exchange information on financial accounts see IEIM401500.

Of these, the agreements with the three Crown Dependencies and with Gibraltar are reciprocal thus imposing obligations on UK Financial Institutions to collect, maintain and report information to HMRC on financial accounts held by individuals and entities resident for tax purposes in those territories. The regulations that require this are [The International Tax Compliance (Crown Dependencies and Gibraltar) (Amendment) Regulations 2015]( (SI 2015/873), (the CDOT Regulations).

The agreements with the remaining six Overseas Territories are non-reciprocal meaning that while HMRC will receive information from these territories there is no requirement for reporting in the opposite direction. Montserrat have, however, indicated that they will be exchanging on a reciprocal basis with the UK under the Common Reporting Standard.

As all the CDOT jurisdictions have adopted the Common Reporting Standard the reports due in 2017 under both regimes in respect of the 2016 reportable period overlap to an extent. Transitional arrangements ensure that reporting in respect of reportable accounts is without duplication. The basic principle is that whichever reporting regime requires more reporting, that is the regime under which an account is reported, see IEIM400555.

For reporting in respect of 2017 and subsequent years, CDOT reporting is fully superseded by the CRS.  Financial Institutions should report under the The International Tax Compliance Regulations 2015 (as amended by 2015 No. 1839, 2016 No. 899, 2017 No. 598) only, pending repeal of the CDOT Regulations.