This information was prepared by tax experts at a non-affiliated third party at Citi’s request for your
general reference only
United Kingdom
The UK taxes UK residents domiciled in the UK on their worldwide income.
Current Trends
The UK government announced further steps to address offshore tax evasion in March 2015. Among other
regulatory actions, the government announced an increase in the ‘naming and shaming’ of tax evaders and a new
offence of strict liability for offshore tax evasion – meaning that ignorance of the law or an absence of criminal
intent may no longer be available defenses. In July 2015, the UK tax authority (HMRC) also issued numerous
consultation documents on its proposals for tougher civil penalties and strict liability criminal offenses. These
consultations were concluded following plans to introduce new legislations.
The UK has also entered into an international withholding tax agreement with Switzerland. Thus, payments of
income and gains from Swiss banks to UK residents may be subject to withholding of UK taxes, unless the UK
resident has opted for reporting.
The UK has agreed to implement automatic exchange of information under the US FATCA regime, the UK CDOT
regime, the EU Savings Directive and the OECD Common Reporting Standard (CRS). See table below for
additional information. These various regimes provide for reciprocal exchanges of information. Thus, under
FATCA, information regarding UK accounts owned by US persons is reported to the US IRS and, likewise,
information regarding US accounts owned by UK residents is reported to the UK tax authority. Similarly, once
CRS is fully implemented, non-residents of the UK with UK accounts will be reported to their CRS country of
residence and, likewise, UK residents with offshore accounts in CRS countries will be reported to the UK tax
authority. It is estimated that there will be approximately 100 CRS reporting countries by 2018.
In July 2015, HMRC announced proposals to make a number of significant changes to the way UK resident nonUK domiciled individuals (“non doms”) are taxed in the UK. One of the key changes proposed is that non doms
who have been UK residents for at least 15 out of the previous 20 tax years will lose access to the remittance
basis of taxation, and will instead be taxed on their worldwide income and gains. These changes were expected
to come into effect on 6 April 2017, however as HMRC has not yet released its response to the recent
consultation, it is currently unclear which provisions will be included in the legislation and whether the changes will
come into effect in April 2017 as planned.
Direct and Indirect Ownership of Investment Accounts
Both the US FATCA regime and the OECD CRS regime require reporting of accounts held directly by the
individual taxpayer and indirectly, through personal investment companies, trusts or foundations. The UK also has
provisions to tax income of controlled foreign corporations at the individual shareholder level, under certain
circumstances.
UK as a Citi Private Bank Booking Center for non-residents of the UK
The UK is a Citi Private Bank Booking Center country. As noted above, for non-residents of the UK with accounts
placed in the UK, directly or indirectly (through intervening legal structures), the above-noted cross-border tax
information exchange regimes will permit or require UK account information to be reported to the direct or indirect
account owner’s country of residence. For example, FATCA and CRS will provide automatic reporting of account
information to the US and to the participating CRS countries (estimated to be 100 countries by 2018).
Exchange of Information Regimes
Applicable Tax Transparency Regime
US FATCA
UK CDOT
EUSD
OECD CRS
Tax Treaty Information
Exchange
For US persons with accounts in UK, UK account information is reported
to the US tax authorities, pursuant to a signed Model 1 IGA, with a
reciprocal agreement for reporting of US account information to the UK
government, with respect to UK residents with accounts in the US

There is annual reporting of information to the UK tax authority, regarding
accounts in the CDOT territories held by UK residents. There is also
reciprocal reporting with respect to accounts in the UK held by residents
of some CDOT territories: Isle of Man, Jersey, Guernsey and Gibraltar.
Crown Dependencies and Overseas Territories (“CDOT”) includes
Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands,
Gibraltar, Guernsey, the Isle of Man, Jersey, Monserrat and the Turks
and Caicos Islands. UK CDOT will be subsumed within CRS in 2017

Annual reporting. EUSD will be subsumed within CRS in 2017
CRS reporting of 2016 account information, to be filed in
Reciprocal
2017, and thereafter, between the UK and CRS-participating countries
exchange of information between the UK and numerous
Reciprocal
countries upon request
Other Tax-Related Considerations
Voluntary Disclosure
Program?
Residents taxed on a
worldwide basis?
None (offshore
disclosure facility was
closed in 31.12.2015)
Following the closure of HMRC’s existing disclosure
facilities at the end of 2015, it is expected that HMRC
will open a final worldwide disclosure facility in advance
of the first data exchange under CRS in September
2017
Yes
The UK has different rules for residents domiciled in
the UK (taxed on worldwide income) and for nondomiciled (not taxed on worldwide income if eligible for
the remittance basis). Income of controlled foreign
corporations may also be taxed at shareholder level
continued
This information is made available for general reference only. It does not constitute legal or tax advice. Citigroup Inc. (Citi), its affiliates, and
its employees are not in the business of providing tax or legal advice to any taxpayer outside of Citi and its affiliates. These materials are not
intended or written to be used, and cannot be used or relied upon, by any such taxpayer for the purpose of avoiding tax penalties. Citi and its
affiliates comply with applicable laws and regulations. This information was prepared by tax experts at a non-affiliated third party at Citi’s
request for your general reference only. While Citi aims to acquaint you with current and imminent tax transparency initiatives around the
globe, we encourage you to seek third party professional advice regarding your personal tax situation.
This information is provided as of August 2016. However as the environment is rapidly changing, please consult with your tax advisor to be
sure you have the up-to-date information. Citi and its affiliates make no representation, recommendation or warranty, express or implied,
regarding the accuracy, adequacy, reasonableness or completeness of the information contained herein.
Note that all references to “resident,” “residents” or “residence” is intended to be a reference to tax resident, tax residents or tax residence,
under the applicable tax laws.