IEIM404120 | Miscellaneous: Mergers and Bulk Acquisitions

Miscellaneous: Mergers and Bulk Acquisitions

Where a Financial Institution acquires accounts by way of a merger or bulk acquisition, the Financial Institution can rely on the status of Account Holders as determined by the predecessor Financial Institution, provided that the predecessor Financial Institution had met its due diligence obligations.

The Financial Institution may continue to rely on the status of the Account Holder as long as it has no reasonable cause to believe that the status is unreliable or incorrect.

HMRC would expect that the Financial Institution undertake a sample review of the acquired accounts to determine that the Account Holders’ status, assigned by the predecessor Financial Institution, is reliable. An Account Holder’s status will need to be verified by the acquiring Financial Institution in accordance with the due diligence procedures should the acquirer have reason to know that it is incorrect or if there is a change in circumstance.

The UK Financial Institution may treat accounts acquired in a merger or bulk acquisition that takes place after 30 June 2014 for FATCA or after 31 December 2015 for the CRS as preexisting accounts for the purposes of applying the identification and documentation procedures.

FATCA Only

Where a Deemed Compliant Financial Institution becomes part of a group as the result of a merger or acquisition, the status of any account maintained by the Deemed Compliant Financial Institution can be relied upon unless there is a change in circumstance in relation to the account.