Conyers Dill & Pearman

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UK FATCA update — Bermuda

The UK government announced late last year that it would seek to make arrangements for the automatic exchange of information with its overseas territories. The UK’s legislation is modelled after and applies similar information sharing techniques to those incorporated in the US Foreign Account Tax Compliance Act (FATCA); such arrangements have come to be known as ‘UK FATCA’ or ‘son of FATCA’.

The Bermuda government announced at the end of November that it has now signed a FATCA‐type intergovernmental model 2 agreement (IGA Model 2) with the UK. Bermuda’s minister of finance, the Honourable ET (Bob) Richards, JP MP, noted that the signing of the IGA Model 2 agreement demonstrates Bermuda’s ‘commitment to tax transparency and the automatic exchange of information and ensure[s] Bermuda’s reputation as the premier international financial jurisdiction in which to do business’.

Financial institutions in Bermuda will be required, pursuant to the terms of the IGA Model 2, to automatically report to UK authorities on an annual basis information on financial accounts that are substantially owned by persons with UK tax-reporting obligations…

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