UK FATCA Compliance for Investment Funds

The United Kingdom has signed intergovernmental agreements (‘IGAs’) with its Crown Dependencies and Overseas Territories in order to improve compliance with UK tax laws, a regime often referred to as ‘UK FATCA’. The jurisdictions that are part of the UK FATCA regime (‘UK IGA jurisdictions’) include a number of common investment fund jurisdictions, such as Cayman Islands, Bermuda, British Virgin Islands, Guernsey, Jersey and Gibraltar. Funds located in these UK IGA jurisdictions become subject to UK FATCA review and reporting obligations over time, so that there is a series of dates by which various steps in the process must be completed. This Alert provides a summary of the relevant UK FATCA implementation dates and reviews compliance requirements for investment funds located in UK IGA jurisdictions.