Countries around the globe are making FATCA updates to regulations every day. Check out the most recent updates from the past week, compiled by our team of tax and compliance experts. Lichtenstein Updates FATCA Reporting Transmission Guide for Tax Year 2015 Lichtenstein has updated their FATCA Reporting Transmission Guide for Tax Year 2015, which contains a number of changes:
- Message Ref ID is provided by the system and cannot be modified by the user
- A Doc Ref ID consists of a Reporting FI’s GIIN, a period (.), and a unique GUID (Globally Unique Identifier) which is calculated automatically by the system
- Example: ABC123.00000.SP.438.AT45R03
- All TIN fields are required (i.e. GIIN, SSN, EIN, etc.) to pass validation
- Lichtenstein’s Tax Administration system:
- Validates the date notation (i.e. YYYY-MM-DD)
- Validates the TIN (EIN, SSN) (9-digits without separators)
- Checks the format of the GIIN
- Prevents special characters pairs as – / * & #
- Converts special characters such as & <>
- When using the system, the Message Ref ID will automatically be filled by the system, and cannot be amended
- TIN is now required to detect Individual Account Holder/Payee or Entity Account Holder/Payee
- Updates have also been made to validation instructions
- New sections regarding FATCA2, FATCA3, and FATCA4 correction messages have been added
- Contact information has been updated
Italy Signs Competent Authority Arrangement With The United States Italy has signed a Competent Authority Arrangement with the United States. The agreement’s purpose is to describe how Italy will administer the FATCA reporting scheme, including the timing of the data exchange, the format of the data exchange, and confidentiality requirements. The arrangement is contemplated in the IGA. Luxembourg Announces Schema Changes Today, Luxembourg released a Newsletter that focuses on changes to the ECHA Circular No. 3. The Newsletter contains the new Circular along with a list of amendments detailing changes to the schema and three annexes. The annexes are: (1) Description of all the fields for Luxembourg’s FATCA schema (XSD_AEOI_LUX_v1.2); (2) Corrections Guide; and, (3) Description of all the fields for schema AEOI_Lux_Return_v0.4. The following schema changes are noted in the Amendment:
- In the “Opening Remarks” section, Luxembourg has changed the contact info for their Office of Withholding Tax
- For Account Balance, Luxembourg is no requiring that the value be greater than zero. Previously, the value could be zero or negative. (See sections 3.1.3 and 3.7.6.)
- In Section 3.4 “File Format,” instructions have been added that the FATCA filing must be encoded in UTF-8 without Byte Order mark (BOM) or the file will be denied.
- Added Section 3.7, which discusses TIN requirements for various account holders.
- For Chapter “4.1 Naming Convention Status File,” a note was added that the ACD will inform the filer if the IRS rejects the data.
Spain Releases Updated Guidance: New Rule For Account Balance Spain has recently released an updated guidance for FATCA reporting. The new version, (2.1), contains two notable additions:
- Previously, the guidance stated that the “AccountBalance” must be greater than zero. On page 14, the new guidance reiterates that general requirement but adds 3 exceptions:
- If payments are included, and zero is the correct value. This is true regardless of the type of FATCA return (i.e. FATCA1, FATCA2, FATCA3, etc.)
- If the FATCA Type is FATCA3 (void data)
- If the FATCA Type is FATCA2 (corrected data), and the correct AccountBalance is zero.
- The new guide also contains two new considerations for corrections, modifications and cancellations, on page 17. They are:
- (Numbered 2 in the guidance), If a FATCA 3 or FATCA 4 is sent for the first time on an account, then the CorrDocRefId must contain the DocRefId from that account to modify or cancel.
- (Numbered 3 in the guidance), In the case of sending a FATCA 2 for the first time to respond to a notice in the CorrDocRefId, always put the DocRefId notified.
Singapore Releases Two New Announcements and an Updated FATCA Filing Process FAQs Page On Thursday, February 11, 2016, the Inland Revenue Authority of Singapore posted two new announcements to its FATCA page and released an updated version of its FATCA Filing Process FAQs page first issued on February 6, 2015. The announcements are the following:
- Singapore Financial Institutions (SGFIs) no longer need to provide contact information to the Inland Revenue Authority (IRAS) because such information can be obtained when a FATCA reporting packet is submitted to IRAS via the IDES.
- Reporting SGFIs that have applied the Alternative Procedures on New Accounts opened between July 1, 2014 and March 17, 2015, are reminded to collect the required self-certification or other documentation for such accounts by March 17, 2016.
The updated FATCA Filing Process FAQs page contains additional information and four new questions:
- Question 8 includes additional information regarding a sample working application developed using the .NET Framework to prepare a FATCA reporting packet for IDES submission. It is available
- Question 15 regarding the difference between Corrected, Amended, and Void Data was added.
- Question 16 regarding the procedures to correct, amend, or void specific records was added.
- Question 17 regarding sample FATCA reporting data files with corrected, amended, or void data was added. The samples are available
- Question 18 regarding Reporting SGFIs and FATCA reporting data files with a combination of different data types was added.
Barbados, Costa Rica, and Romania Sign Competent Authority Arrangements Barbados, Costa Rica, and Romania have each signed a Competent Authority Arrangement with the United States. The agreement’s purpose is to describe how each country will administer the FATCA reporting scheme, including the timing of the data exchange, the format of the data exchange, and confidentiality requirements. The arrangement is contemplated in the IGA. To access the CAAs, please click here:
Want More FATCA Updates? Don’t forget to sign up for the Sovos Blog and monthly newsletter for these and other important updates regarding FATCA, CDOT, and CRS.
