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UK April 29 FATCA / CRS Updates

  • Elizabeth A. McMorrow
  • 42 minutes ago
  • 2 min read

On April 29, 2026, the United Kingdom HM Revenue & Customs (UK HMRC) published updates to its International Exchange of Information Manual. The updates include information related to partnerships, specified electronic money products (SEMPs), CRS reportable jurisdictions, and compliance penalties.


Partnerships

HMRC clarified that a UK Financial Institution (FI) includes an FI that is a Limited Partnership formed in the UK or a Limited Liability Partnership incorporated in the UK. This clarification will not be applied retroactively. An FI that becomes a UK FI due to the HMRC clarification is required to register in the UK AEOI portal by January 31, 2027.


SEMPs

A SEMP which ceases to be a SEMP during a given year must be treated as a SEMP until December 31 of that year. This includes if the SEMP becomes a “cryptoasset” pursuant to CARF. The product will be a SEMP for the entirety of Year 1 and then report under CARF as a cryptoasset in Year 2 (if it is still a cryptoasset).


CRS Reportable Jurisdictions

Cameroon and Morocco have been removed from the list of reportable jurisdictions for Y2025 reporting due by May 31, 2026. HMRC asks accounts held by tax residents of Cameroon and Morocco not be reported. However, HMRC recognizes data may have already been prepared and asks the data be included rather than an FI fail to timely report.


Penalties

In 2025, HMRC issued a revised penalty framework which applies to failures occurring on or after July 16, 2025. This week, HMRC added an example paragraph to illustrate timing of failure and which penalty regime applies.


Additionally, HMRC expanded its explanation of the application of penalties for failure to apply due diligence procedures to Preexisting Accounts and New Accounts.


Click to read the complete HMRC April 29 updates.


For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.

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