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HMRC internal manual

International Exchange of Information Manual

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HM Revenue & Customs
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NRFI: FATCA Only: Non-Profit Organisations

NRFI: FATCA Only: Non-Profit Organisations

Where a non-profit organisation is a Financial Institution, which is most likely to happen if it falls within the definition of Investment Entity [see IEIM400760 and IEIM400780] by virtue of having its financial assets managed by a Financial Institution, it is potentially in scope as a Reporting Financial Institution for CDOT and CRS/DAC reporting.

Under FATCA, such non-profit organisations are Deemed Compliant Financial Institutions and are not required to register with the IRS or report to HMRC.

Under both CDOT and CRS/DAC such non-profit organisations are required to carry out due diligence processes to identify and report on any Reportable Persons. Where the non-profit organisation is not a Financial Institution it will be a NFE. Under all three regimes the effect is to treat the NFE as active [see IEIM404040]. They are specifically defined as active under FATCA and CRS/DAC and the Controlling Persons are exempted from being reported on under CDOT.