Paper Certificate shares / Common Reporting Standard

[Anther]

What is the situation with a person who lives in France and who holds shares in large UK plc companies in Paper certificate form with regard to the Common Reporting Standard ?

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

Or are UK Registrars exempt from the Common Reporting Standard ?

If UK Registrars are not exempt, it must be a huge reporting task for them given the constant daily changing of a share register for a large UK plc, with potentially many thousands of paper certificate shareholders on the register with an overseas address.

[dspp]

What is the situation with a person who lives in France and who holds shares in large UK plc companies in Paper certificate form with regard to the Common Reporting Standard ?

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

Or are UK Registrars exempt from the Common Reporting Standard ?

If UK Registrars are not exempt, it must be a huge reporting task for them given the constant daily changing of a share register for a large UK plc, with potentially many thousands of paper certificate shareholders on the register with an overseas address.

Anther,

In partial response, and without knowing the detail at all, the little I do know is that within the EU the tax authorities are working behind the scenes quite hard to inform each other of financial affairs of taxpayers. This is also going on outwith the EU but not quite as fast. However I do not know the detail on this so I am interested in any responses from more knowledgeable people.

regards, dspp

PS. Wearing my Mod hat this thread is unlocked so that people can answer you here, and the other thread is locked but with a redirect link so people know only to come here. And an incorrect redirect link someone helpfully tried to put up has been retired. Phew !

[Anther]

What is the situation with a person who lives in France and who holds shares in large UK plc companies in Paper certificate form with regard to the Common Reporting Standard ?

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

Or are UK Registrars exempt from the Common Reporting Standard ?

If UK Registrars are not exempt, it must be a huge reporting task for them given the constant daily changing of a share register for a large UK plc, with potentially many thousands of paper certificate shareholders on the register with an overseas address.

Anther,

In partial response, and without knowing the detail at all, the little I do know is that within the EU the tax authorities are working behind the scenes quite hard to inform each other of financial affairs of taxpayers. This is also going on outwith the EU but not quite as fast. However I do not know the detail on this so I am interested in any responses from more knowledgeable people.

regards, dspp

PS. Wearing my Mod hat this thread is unlocked so that people can answer you here, and the other thread is locked but with a redirect link so people know only to come here. And an incorrect redirect link someone helpfully tried to put up has been retired. Phew !

dspp,

Thanks for the reply. There does not seem to be any information available anywhere on the internet about such a situation like this with UK Registrars and paper share certificates and an overseas address, so as you say hopefully some knowledgeable people here may know the answer.

Regards, Anther

[genou]

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

This is just an interested amateur response. Have a look at https://www.revenue.ie/en/companies-and ... rd-crs.pdf ( why I found it via Ireland only Google knows ) . You hold Financial Assets with a Custodial Institution, in which case there is a reporting obligation on the CI , i.e. registrar .

Why is this an issue?

[Anther]

Would a UK Registrar be considered to be a Custodial Institution under CRS ? They keep the share register but they do not really have any custody of shares such as brokers for example.

[genou]

Would a UK Registrar be considered to be a Custodial Institution under CRS ? They keep the share register but they do not really have any custody of shares such as brokers for example.

It looks like you are right - https://www.icsa.org.uk/assets/files/re ... v-2012.pdf suggests that they are out of scope for FATCA, which would in turn suggest that they are out of scope for automatic exchange.

[gryffron]

Equiniti website says:
"Equiniti has developed an in-house CRS solution to ensure that all of the required investor data for our impacted clients has been captured and stored appropriately and we are preparing to make our first returns to HMRC next month."

Presumably they wouldn't need to report day-to-day, but only when dividends/distributions are paid out.

Important to note that paper share certificates are wall decorations. Only the name/address on the share register matters. So how the shares are held wouldn't matter to the registrar.

Gryff

[Alaric]

Important to note that paper share certificates are wall decorations. Only the name/address on the share register matters. So how the shares are held wouldn't matter to the registrar.

If you hold through a platform or Broker, the registrar will only know name and address if the platform tells them. Similarly if resident abroad and holding paper certificates, is it not possible there to put them in the name of a nominee?

The register of shareholders is a public document, so there's a security issue of sorts in being explicitly named on it.

[Anther]

"Equiniti has developed an in-house CRS solution to ensure that all of the required investor data for our impacted clients has been captured and stored appropriately and we are preparing to make our first returns to HMRC next month."

Presumably those impacted Equiniti clients will be those who have a direct customer relationship with Equiniti, such as those who have a Shareview Account with Equiniti and who therefore use Equiniti as a custodian.

https://www.shareview.co.uk/4/Info/Port ... reForm.pdf

This would presumably not include those shareholders of large UK plc companies who hold their shares in Paper Certificate form, with an overseas address.

[XFool]

What is the situation with a person who lives in France and who holds shares in large UK plc companies in Paper certificate form with regard to the Common Reporting Standard ?

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

Or are UK Registrars exempt from the Common Reporting Standard ?

No they are not exempt. Several people here, including me, have in the past received letters wrt CRS. It was just a simple matter of one off filling in a paper form or online. Fill in and forget, AFIAK. I have no real idea what the Registrars do with the information, send it to HMRC I expect.

This was in relation to securities that were domiciled abroad. As I live in the UK I do not know how this all works for people living abroad.

viewtopic.php?f=49&t=3959&p=39264&hilit=fatca#p39264

[Anther]

What is the situation with a person who lives in France and who holds shares in large UK plc companies in Paper certificate form with regard to the Common Reporting Standard ?

Are UK Registrars such as Computershare and Equiniti required to report all of their paper certificate shareholders with an overseas address (such as France) to HMRC every year ?

Or are UK Registrars exempt from the Common Reporting Standard ?

No they are not exempt. Several people here, including me, have in the past received letters wrt CRS. It was just a simple matter of one off filling in a paper form or online. Fill in and forget, AFIAK. I have no real idea what the Registrars do with the information, send it to HMRC I expect.

This was in relation to securities that were domiciled abroad. As I live in the UK I do not know how this all works for people living abroad.

viewtopic.php?f=49&t=3959&p=39264&hilit=fatca#p39264

The thread referred to does not mention anything about the situation of UK Registrars of UK plc companies with paper certificate shareholders with an overseas address. Were the paper certificate shareholdings in standard FTSE companies such as Barclays plc or Lloyds plc or Next plc, or in some other type of company ?

[XFool]

The thread referred to does not mention anything about the situation of UK Registrars of UK plc companies with paper certificate shareholders with an overseas address. Were the paper certificate shareholdings in standard FTSE companies such as Barclays plc or Lloyds plc or Next plc, or in some other type of company ?

As one registrar mentioned "Failure to validly complete this form will result in you being reported onwards to the relevant local tax authority." - in my case HMRC - I assume the same applies if you are domiciled abroad.

From memory they were ITs domiciled outside the UK. I also may not have held paper certificates in every case.

[XFool]

...I suspect, rather than anything to do with paper share certificates, it may be more a matter of where the registered investor is domiciled for tax purposes and where the company is registered for tax purposes that is the issue.

[dspp]

My understanding is that, historically, holders of paper share certificates were less likely to churn than those who were online. Therefore even if there are large numbers of them, if this 'fact' is true (and it appears reasonable & plausible given human nature), then it would perhaps not be as great a reporting workload problem as the OP opined. (my understanding is based on something I was told over a decade ago).

I am intrigued as to why the question is being asked. It might be out of a zealous desire to see the reporting rules fully enforced; or to shift a workload to someone else; or - ahem - to figure out whether a tax reporting loophole might be capable of exploitation; combined perhaps with a 'privacy' argument; or maybe there is some other fully understandable reason. I appreciate it is not necessarily pertinent in answering the question (which has not so far been fully answered) but nevertheless it piques my curiosity.

regards, dspp

[XFool]

...I believe (correctly or not) the "answer", to the above post at least, is in my previous post. It's about tax domicile.