Man and AEOI Compliance

Governments around the world have introduced new information-gathering and reporting requirements for financial institutions with which Man Group and the Funds we manage are obligated to comply. These requirements are collectively referred to as Automatic Exchange of Information (AEOI) requirements.

AEOI requirements have been introduced to provide tax authorities globally with greater transparency over financial assets (and associated income) held offshore. This page provides further information on AEOI requirements and what it means for you.

 
AEOI regulations

AEOI requirements arise from two principle sets of regulations, which have been adopted in over 100 jurisdictions globally, namely US FATCA (Foreign Account Tax Compliance Act - introduced by the US Government) and the CRS (Common Reporting Standard – introduced by the Organisation for Economic Co-operation and Development, “OECD”).

 
What are Man funds required to do?

Under these regulations Man, and other similar Financial Institutions, are obliged to determine where you are “tax resident” and, for FATCA, whether you are a US person. Financial Institutions then have to complete reporting to relevant tax authorities where investors are identified to be tax resident outside of the jurisdiction where an investment is held (or to be a US person). This will require Man to:

  • Collect and review tax information during on-boarding of all new clients through collection of valid self-certifications and/or US Inland Revenue Service (IRS) W-series forms from investors;
  • Review information held in respect of our existing investor base and request additional information from investors where necessary;
  • Complete annual reporting to relevant tax authorities in respect of those investors identified as being a US person (under FATCA) or CRS reportable persons (under CRS) based on the their tax residency and as per the requirements of the relevant regulations.
 
Potential impact on investors

AEOI regimes may impact you whether you are an individual investor or an entity/business investor. The impact will typically depend on the type of investment you hold, where your investment is held and where you live or operate as a business.

We may request you to complete self-certifications and/or IRS W-series forms in order to help us correctly classify you for the purposes of the regimes, and where appropriate will report necessary information securely to relevant tax authorities.

It is therefore important that the information you provide is accurate and valid in order to help us establish your tax status. We may not be able to accept your investment if you choose not to provide the requested information or any existing investments may be restricted on redemptions.

US FATCA Rules originally intended enforcing compliance with FATCA by imposing a 30% US tax on US-source payments such as dividends, interest and sales proceeds paid to non-participating FFIs (i.e. financial institutions that have not signed an agreement with the IRS). As the US has now signed inter-governmental agreements with over 100 jurisdictions that mandate compliance with FATCA, withholding should not apply however, it cannot be completely ruled out.

 
Potential Impacts for Investors

The investment process requires a request and verification of detailed tax information on investors. Where appropriate this information will be communicated securely to appropriate tax authorities. Consequently we may not accept your investment if you choose not to send us the tax documentation requested to establish your tax status.

 
Additional information

If you require any further information or have any questions concerning the FATCA or CRS regulations, please refer to the website links below or speak to a tax advisor. Please be aware that we are not in a position to provide tax advice.

 

Useful information websites:

Self-Certification forms: If you are asked to complete a self-certification form(s), you should be provided with the relevant entity or individual form (these are either standalone forms or as part of the application form for subscription into the fund). Please contact your relationship service provider if you do not have these forms to complete.

Taxpayer Identification Numbers (TIN): Self-certification forms include requests for TIN information. Your TIN is a unique combination of letters and/or numbers assigned to you/your entity. Some countries do not issue a TIN, but may rely on other issued numbers such as social security/national insurance numbers or company registration numbers for entities. You may need to provide these if requested. The OECD has published a list of the acceptable Taxpayer Identification Number (TIN) formats: http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-identification-numbers/

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