It is anticipated (here) that the HMRC will soon announce that UK Financial Institutions (“UKFIs”) who have registered with the IRS to uphold FATCA compliance, but do not have US Specified Persons on which to report, will not be required to file nil returns with the HMRC.
The HMRC intends to release further information on this amendment, although registered UKFIs may still choose to make nil returns until this amendment takes effect (anticipated for the end of April 2015). This amendment will not impact any UKFIs that are required to complete returns detailing information about US Specified Persons, due with the HMRC by the end of May 2015.
The HMRC will also confirm that holding and treasury companies are not considered to be UKFIs.
It remains to be seen whether other countries follow the UK’s approach to nil returns.
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