Mazars welcomed the opportunity to comment on this important consultation. Our responses focused on the following areas:
- It is undesirable tointroduce new regulations at the same time as the costs of FATCA arestill being felt in the financial services sector;
- We feel HMRC should focus on tailoring their approach using a more risk based approach,addressing the common problems in the UK, rather than adopting the FATCA legislation;
- Like FATCA, the language of the proposal is heavily focused on banking and not directed towards the intended users; and
- The proposals are grounded in FATCA; it would be far more cost-effective to see lessons learned from the implementation of FATCA, to avoid the same mistakes being made.