HMRC internal manual

International Exchange of Information Manual

IEIM400930 - Non-Reporting Financial Institutions: Government Entity

NRFI: Government Entity

Government entities are Non-Reporting Financial Institutions (NRFI) for both regimes.

It is a defined term in the CRS and any entity that falls within the definition is a NRFI. Government entity means the government of a jurisdiction, any political subdivision of a jurisdiction, or any wholly owned agency or instrumentality of a jurisdiction or any one or more of the foregoing (each, a “Government entity”). This category is comprised of the integral parts, controlled entities and political subdivisions of a jurisdiction.

The IGA with the USA treats UK Governmental organisations, any political subdivision of the UK Government or any wholly owned agency or instrumentality of any one or more of the foregoing as NRFI – essentially the same definition as for the CRS. The IGA then goes on to specify certain entities that are included in this definition, these being –

• The Devolved Administrations as per:

  • the Northern Ireland Act 1998 (updated by The Northern Ireland (St Andrews Agreement) Acts 2006 & 2007, and the Northern Ireland Act 2009)
  • the Scotland Act 1998
  • the Government of Wales Act 2006

• Local Government Authorities as per:

  • Section 33 of the Local Government Act 2003

  • The Local Government Act (NI) 1972 (as amended by The Local Government (Miscellaneous Provisions) Act (NI) 2010 and Local Government Finance Act (NI) 2011)
  • The Local Government etc. (Scotland) Act 1994
  • The Local Government (Wales) Act 1994

Other examples of entities that would be within these definitions would include Government financing programmes and agencies which may provide loans directly or insure or guarantee loans granted by commercial lenders where this is intended to promote international trade and development.