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HMRC internal manual

International Exchange of Information Manual

Financial Institutions: Non-Reporting Financial Institutions: FATCA only: Introduction

NRFI: FATCA Only: Introduction

Under FATCA, Non-Reporting Financial Institutions (NRFI) are categorised as Deemed Compliant Financial Institutions. UK Financial Institutions can be within this category by satisfying the requirements set out in Annex II of the IGA which covers:

i.              Non-profit organisations [see IEIM401000]: Under the agreement these are to be regarded as Deemed Compliant Financial Institutions and will not have any reporting requirements in relation to any financial accounts that they may hold. This applies to:

•             Any entity registered as a charity with the Charity Commission of England and Wales

•             Any entity registered with HMRC for charitable tax purposes

•             Any entity registered as a charity with the Office of the Scottish Charity Regulator

•             Any Community Amateur Sports Club if registered as such with HMRC


ii.             Financial Institutions with a Local Client Base [see IEIM401020] which will have a reduced reporting requirement if they meet the relevant criteria.

Alternatively an entity can be a Deemed Compliant Financial Institution by satisfying the requirements in the US regulations for being a:

•             Registered Deemed Compliant Financial Institution

•             Certified Deemed Compliant Financial Institution, or

•             Owner Documented Financial Institutions.


In terms of Deemed Compliant Financial Institutions, only a registered Deemed Compliant Financial Institution or in certain circumstances a Local Client Base Financial Institution, are required to register with the IRS.