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HMRC internal manual

International Exchange of Information Manual

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Financial Accounts: Excluded Accounts: Introduction

Financial Accounts: Excluded Accounts: Introduction

All the regimes for automatic exchange of information allow for various categories of account to be excluded from being reportable financial accounts. These are excluded because they have been identified as carrying a low risk of use for tax evasion, generally because of the regulatory regimes under which they function.

In the Intergovernmental Agreements between the UK and the USA, Crown Dependences and Overseas Territories, the excluded accounts are listed in Annex II of each agreement [CDOT/ USA].

For reporting under the Common Reporting Standard and the EU Directive on Administrative Cooperation in Tax Matters, the list of excluded accounts can be found in the CRS and the DAC, details of the conditions for being an excluded product for both are included in the commentary to the CRS. Certain products are specifically excluded by UK domestic legislation in Schedule 2 of the International Tax Compliance Regulations 2015 (SI878/2015) as amended by The International Tax Compliance (Amendment) Regulations 2015 (SI1839/2015). The agreements for automatic exchange provide for the list of excluded accounts to be updated, either to allow for other low risk products to be added or to remove products that are no longer regarded as low risk.