The International Tax Compliance (Amendment) Regulations 2025 compel UK investment managers and other financial institutions to register with HMRC by 31 December 2025, even if they have no reportable financial accounts. The new rules catch fund managers authorised by the Financial Conduct Authority, portfolio managers, alternative investment fund managers and other entities managing investments on a discretionary basis. The regulations also apply to trustee-documented trusts, regardless of where their account holders are resident. A new penalty framework applies for failure to register and other compliance breaches.
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