BVI US And UK FATCA Implementation - Entity Classification And Registration

On 30 June 2014, the British Virgin Islands ("BVI") government signed a Model 1B (i.e. non-reciprocal) intergovernmental agreement with the United States (the "US IGA").  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act ("FATCA") in the BVI.  The BVI government had, on 28 November 2013, signed an intergovernmental agreement with the United Kingdom which made similar provisions for the reporting of tax information to HM Treasury (the "UK IGA" and, together with the US IGA, "the IGAs").  Each of the IGAs is largely similar in scope and effect.  The process of preparing the supporting BVI legislation, regulations and guidance notes has now begun in earnest, with draft guidance notes being circulated at the end of July 2014.