This practical note provides an introduction to inter-secretary agreements and their important provisions. This practical note: Does explain the purpose of an intercretor agreement and whether an intercrecreditor agreement was used instead of a priority or subordination act- does it represent links to a company`s statutes? The “Constitution” of a company is defined in the Companies Act 2006 (CA 2006) as: the company`s statutes and all decisions and agreements relating to the incorporation of a businessThe definition of the “Constitution” 2006 is not exhaustive and this practice provides a comprehensive overview of the application of the Foreign Account Tax Compliance Act (FATCA) to UK loan contracts. The IGAs, which the United Kingdom has concluded with the Crown Dependencies (and Gibraltar), are totally reciprocal and therefore require national legislation in both the United Kingdom and the Crown Dependencies to implement the agreements. On 31 March 2014, the implementation rules for the IGA, the International Tax Compliance (Crown Dependencies and Gibraltar) Regulations 2014, came into force for the Uk and the regulations have been amended since then (SI 2015/873). In accordance with the Taiwan Relations Act, the parties to the agreement are the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States. Many other governments, including CDTOs, have entered into or entered into similar agreements with the United States. The United Kingdom has also entered into similar agreements with CDTOs to allow HMRC to inquire about the offshore accounts of UK residents. FATCA requires foreign financial institutions (FFIs) to report information to the IRS on the financial accounts of U.S. taxpayers or foreign companies in which U.S. taxpayers hold a significant stake. FFI are invited to either register directly with the IRS to comply with FATCA rules (and, if applicable, FFI agreements), or to comply with FATCA agreements (IGA), which are considered effective in their legal systems.