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HMRC internal manual

International Exchange of Information Manual

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Undocumented Accounts

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Undocumented Accounts

CRS and DAC Only

An undocumented account can only exist for CRS and DAC reporting purposes.

Lower Value Accounts

An undocumented account which is a lower value account only exists where all three of the following criteria are met:

  • The only indicators that the Financial Institution hold from their electronic record search are
    • a “hold mail” instruction, or
    • an “in-care-of” address in a CRS Reportable Jurisdiction
  • No other address or indicia of residence are identified for the Account Holder
  • The Financial Institution has, in the order most appropriate to the circumstances
    • carried out a paper record search for indicia and no indicia were found, or
    • tried to obtain a self-certification or other documentary evidence from the Account Holder to establish the jurisdiction of tax residence of the Account Holder, and has been unable to obtain these.
High Value Accounts

An undocumented account which is a high value account only exists where all three of the following criteria are met:

  • The only indicators that the Financial Institution hold from their electronic record search and paper record search are
    • a “hold mail” instruction, or
    • an “in-care-of” address in a CRS Reportable Jurisdiction
  • No other address or indicia of residence are identified for the Account Holder
  • The Financial Institution has tried to obtain a self-certification or other documentary evidence from the Account Holder to establish the jurisdiction of tax residence of the Account Holder, and has been unable to obtain these.
Reporting and reviewing undocumented accounts

In these circumstances the Financial Institution is required to treat the Account Holder as an undocumented account which must be reported as such to HMRC using country code GB.

Where the Financial Institution has identified and reported an account as an undocumented account the Financial Institution must repeat the enhanced review for high value individual accounts annually until the account ceases to be undocumented.