UK: HMRC guidance on redaction of information under AEOI on human rights ground

Guidelines instructing financial institutions and individuals on steps to take when there are human rights concerns

HMRC guidance on redaction of information under AEOI on human rights ground

HMRC issued on 12 December 2022, guidelines instructing financial institutions and individuals on the steps to take when there are human rights concerns with information being transmitted under the automatic exchange of information (AEOI).

Financial institutions and individuals need to apply to HMRC for a redaction of information if they have cause to believe that the information required by the AEOI agreements may endanger someone's rights. Financial institutions are still required to provide all information to HMRC, since it is required by the AEOI regimes. However, if HMRC agrees to the redaction, HMRC will take out all information about that person, or those persons, from the information that is sent to other jurisdictions.

Financial institutions or individuals who wish to apply for redaction need to complete the application form found under IEIM406120. Financial institutions or individuals need to use the blank area in section F to highlight any additional relevant information. They also need to make sure that any necessary supporting documentation is provided with the application. A separate form is required to be completed for each relevant jurisdiction for which a redaction is required.

An application for redaction can be submitted at any time by sending information to the mailbox— Information relating to the previous calendar year must be submitted by 31 May each year. To provide HMRC time to assess before the reporting deadline, applications must be submitted by 30 April following the first year that the financial institutions or an individual becomes aware of the threat. After this date, if a financial institution or an individual becomes aware of a threat, they must get in touch with HMRC as soon as possible so that the situation may be examined before any data is shared. Receiving an application after 30 April will not be considered grounds for rejection.

Read a December 2022 report [PDF 655 KB] prepared by the KPMG member firm in the UK


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