The International Tax Compliance (Amendment) Regulations 2025 impose a new requirement on all entities that are reporting financial institutions for purposes of the UK's automatic exchange of tax information (AEOI) regime – which includes UK investment managers – to register with HMRC by 31 Dec. 2025.
Prior to the introduction of this new HMRC registration requirement, UK investment managers were generally not subject to any reporting obligations under the AEOI regime. This was on the basis that UK investment managers, whilst reporting financial institutions, were usually treated as reporting financial institutions that did not maintain any "financial accounts", and thus had no information to report on an annual AEOI return (HMRC not generally requiring "nil returns").
Whilst this should remain the case, so that UK investment managers will continue not to be required to submit annual AEOI returns to HMRC, UK investment managers will be subject to the new, one-time, HMRC registration requirement, on the basis that they are (technically) reporting financial institutions.
UK investment managers should therefore ensure that they register with HMRC as a reporting financial institution by 31 Dec. 2025.
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