AEOI Updates: Jan. 6 – Jan. 20
Automatic Exchange of Information (AEOI) legislation is constantly evolving worldwide as the standard is rolled out around the world. The Sovos research team continually monitors new regulations and updates across the globe and publishes them in our Taxport Compass tool. Here are some important changes that occurred in recent weeks:
IRS Releases New FFI Agreement
The IRS published its new foreign financial institutions (FFI) Agreement in Revenue Procedure 2017-16. The agreement details important reporting and due diligence requirements for FIs in Model 2 intergovernmental agreement (IGA) jurisdictions and those jurisdictions without IGAs. It also includes temporary regulations that impact compliance with regard to Foreign Account Tax Compliance Act (FATCA) withholding, due diligence and reporting.
The Bahamas Publishes CRS Legislation
The Bahamas’ released its Common Reporting Standard (CRS) legislation, which is in effect as of Jan. 1, 2017. It requires Bahamian FIs to implement due diligence and reporting requirements set forth in the CRS, and to register by the end of March. Since the Bahamas is a late adopter, reporting will begin in 2018.
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Bahrain Signs Model 1B IGA
The United States Treasury recently published a Model 1B IGA between the U.S. and Bahrain to its website. Previously, the Treasury listed Bahrain as having an agreement in substance. The Central Bank of Bahrain, the competent authority in charge of administering FATCA, has yet to release guidance.
Curaçao Revises FATCA and CRS AEOI Manual
The Curaçao Ministry of Finance published Version 2.1 of its FATCA and CRS Automatic Exchange of Information (AEOI) XML Manual. The manual provides instructions to properly format electronic returns for both FATCA and CRS. Curaçao is an early adopter jurisdiction, which means FIs will have to submit their CRS returns this year along with their FATCA.
Ireland and Jersey Update Lists of Participating Jurisdictions
Ireland and Jersey have both updated their lists of Participating Jurisdictions. These lists are important reference tools for FIs, as they must make sure to keep track of certain accounts — like Passive NFEs and Investment Accounts — using the look-through treatment if their countries of residency are not on the Participating Jurisdiction list