HMRC internal manual

International Exchange of Information Manual

Financial Accounts: Equity and Debt Interests

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

Financial Accounts: Equity and Debt Interests

Equity and debt interests are financial accounts only to the extent that they are interests in an Investment Entity [link IEIM400760].

Where an entity is an Investment Entity solely because it acts on behalf of a customer by investing, managing or administering financial assets in the name of the customer, the debt and equity interests in the Investment Entity are not financial accounts provided it only renders investment advice to, or manages portfolios for, the customer.

An equity interest may vary depending on the nature of the Investment Entity. In the case of an Investment Entity that is a partnership an equity interest is either a capital or profits interest in the partnership.

In the case of a trust an equity interest is any interest held by a person who is treated as a settlor or beneficiary of all or any part of the trust, or any other natural person exercising ultimate effective control over the trust [see IEIM403400].

  • A Reportable Person [see IEIM403440] will be treated as being a beneficiary of a trust if such a person has the right to receive a mandatory distribution from the trust. This distribution can be received either directly or indirectly, for example through a nominee; or


  • Receives a discretionary payment from the trust. Again this receipt can be either directly or indirectly from the trust.