Financial institutions around the world, including LBIE, are now subject to exchange of information regulations and disclosures to relevant tax authorities. As a result of these regulations, in May 2015 LBIE was required to undertake due diligence and in some cases reporting to the UK tax authority (HMRC) in relation to LBIE counterparties under US FATCA. In 2016 and 2017, in addition to US FATCA, further regulations will apply to UK financial institutions as a result of the introduction of UK FATCA and CRS (“Common Reporting Standard”).
In order to limit the information requests LBIE sends to its counterparties, whilst at the same time ensuring LBIE meets its ongoing due diligence requirements under US FATCA, UK FATCA and CRS, over the next few weeks LBIE will be contacting a large majority of its counterparties to request self-certification and US tax forms to be completed and submitted back to LBIE. It is intended, subject to counterparty’s circumstances not changing, for this to be a one-off initiative. Failure of a counterparty to complete and submit these forms to LBIE, may result in a requirement for LBIE to disclose counterparty information to relevant tax authorities.
If a counterparty has any questions about how to complete these forms they should contact their tax advisor.
Notwithstanding the intention for this to be a one-off initiative, there may be instances where LBIE is required to request further information from a counterparty in due course.
Restructuring and Insolvency Partner, UK Head of Insolvency, PwC United Kingdom
Tel: +44 (0)7974 332659