UK: Revised penalty framework; updated International Exchange of Information manual
Reports about recent tax developments under the FATCA and CRS regimes
The KPMG member firm in the UK has prepared reports about the following tax developments under the FATCA and common reporting standard (CRS) regimes.
- HM Revenue and Customs (HMRC) on June 25, 2025, issued the International Tax Compliance (Amendment) Regulations 2025, introducing amendments to the International Tax Compliance Regulations 2015. Among other amendments, the penalty framework has been substantively revised to address various non-compliance scenarios. Under the amended provisions, a penalty may be imposed when a reporting financial institution or UK representative fails to comply with the obligations under the International Tax Compliance Regulations. Read the August 2025 report.
- HMRC on August 5, 2025, updated its International Exchange of Information Manual (IEIM) to revise section IEIM402880 (Due Diligence - Pre-Existing Individual Accounts - Lower Value Accounts - Curing Indicia). The update clarifies the process for curing unambiguous indicia of a U.S. place of birth under FATCA. In addition, HMRC on August 6, 2025, updated section IEIM905400 (Circumstances in which a Penalty will not Apply) to provide that no penalty will apply for reporting inaccurate or incomplete information where the individual has taken reasonable care to comply with the requirements. Read the August 2025 report.