HMRC has now published in final form the first part of its International Exchange of Information Manual, which incorporates HMRC’s guidance on FATCA and the OECD Common Reporting Standard (CRS).

Section IEIM400000 covers automatic exchange of information, which replaces the draft published for informal consultation in September 2015. 

This guidance is intended to provide HMRC staff with an understanding of the requirements that UK financial institutions must fulfil to comply with obligations under the four current sets of legislation for automatic exchange: FATCA; the CRS; the Crown Dependencies and Gibraltar Regulations; and the EU Directive on Administrative Cooperation in Tax Matters (DAC).

It is also intended as a reference source for financial institutions and tax professionals for use alongside the commentaries to the CRS.

The guidance explains that the CRS is imposed in Europe via the DAC. As a result, it is the DAC which governs the obligations imposed on reporting financial institutions in the UK. The UK guidance on CRS cannot extend or restrict the scope of CRS as implemented by the DAC.