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HMRC internal manual

International Exchange of Information Manual

From
HM Revenue & Customs
Updated
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Reportable Information: Non-Participating Financial Institutions: US Withholdable Payments

Reportable Information: Non-Participating Financial Institutions: US Withholdable Payments

Financial Institutions will also need to report up the payment chain when a Non-Participating Financial Institution is the recipient of specific US source payments. This requirement will fall on Financial Institutions other than those that have elected to act as qualifying intermediaries with primary withholding responsibility, withholding foreign partnerships or withholding foreign trusts.

Where such a financial institution pays, or acts as an intermediary for the payment of, a US source withholdable payment to a Non-Participating Financial Institution, the Financial Institution is required to provide information to the “immediate payor” of that income. The immediate payor is the person with withholding and reporting obligations to the US authorities.

The information that must be provided in respect of the payment is that required for withholding and reporting to occur.