HMRC’s guidance notes will need to be updated again following the publications of the last set of regulations by the IRS. The following amendments are particularly noteworthy.
The updated guidance explains that the application of provisions in agreements which differ from the UK/US agreement will be covered in supplementary chapters. However when no additional guidance is provided the provisions of similar agreements should be applied in the same way as under the UK/US agreement.
It also provides that a subsidiary or a branch of a non-UK entity carrying on a business as a custodial or depositary institution (or other relevant services) will be a reporting UK financial institution.
The guidance also contains a new paragraph on securitisations. Special purpose vehicles created to hold debt until maturity or liquidation will be regarded...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
HMRC’s guidance notes will need to be updated again following the publications of the last set of regulations by the IRS. The following amendments are particularly noteworthy.
The updated guidance explains that the application of provisions in agreements which differ from the UK/US agreement will be covered in supplementary chapters. However when no additional guidance is provided the provisions of similar agreements should be applied in the same way as under the UK/US agreement.
It also provides that a subsidiary or a branch of a non-UK entity carrying on a business as a custodial or depositary institution (or other relevant services) will be a reporting UK financial institution.
The guidance also contains a new paragraph on securitisations. Special purpose vehicles created to hold debt until maturity or liquidation will be regarded...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")