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HMRC internal manual

International Exchange of Information Manual

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HM Revenue & Customs
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Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Introduction

Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Introduction

In determining whether an Account Holder of a Lower Value Account is a Reportable Person [see IEIM403440] for CRS and DAC purposes Financial Institutions have two options for making such a determination. They can apply either

  1. A residence address test [see IEIM402680], or
  2. An electronic record search [see IEIM402780].

 

In the event that the Financial Institution applies the residence address test and this does not determine the residence of the individual Account Holder then it must also apply the electronic record search.

Financial Institutions can apply the residence address test to all Lower Value Accounts or, separately, to any clearly identified group of such accounts. A group of accounts may, for example, be those maintained by a particular line of business or those maintained in a particular location.

Financial Institutions may also opt to go straight to an electronic record search for indicia of tax residence without first applying the residence address test.

The US and CDOT IGAs do not allow for the residence address thus only the electronic record search is permitted.