Weekly FATCA Update: April 9-15, 2016

April 15, 2016

Singapore Publishes FATCA Updates for Forms and Documents, set to Commence FATCA Return Filing for 2015

Singapore has made a number of recent updates related to FATCA which are as follows:

  • FATCA Return Filing for Reporting Year 2015 will begin TODAY, April 15, 2016. All Reporting Singaporean Financial Institutions (SGFI’s) are required to submit a FATCA Return to the Inland Revenue Authority of Singapore (IRAS) by May 31, 2016.
  • IRAS has also released an updated Nil Reporting Form.
  • FATCA Filing FAQ’s: A Reporting Singaporean Financial Institution (SGFI) that does not maintain any U.S. Reportable Accounts in the 2015 Reporting Year is required to submit a nil return to IRAS. Financial Institutions must do so by submitting either the Nil return XML file through IDES or a paper return to IRAS. The paper nil return for 2015.
  • IRAS FATCA Supplementary Instructions, XML Element “Payment”: If an account holder has not received a particular payment type that is relevant to the account held, a zero amount may be reported. If a particular payment type is irrelevant to the account type (e.g. dividend, gross proceeds credited will not be relevant for a deposit account), the payment information may be omitted.


South Africa Temporarily Closes FATCA Testing Portal

South Africa has temporarily closed its FATCA Testing Portal. From April 8, 2016 until tomorrow, April 16, 2016, the FATCA Testing Portal will be unavailable. Files must not be submitted during this time as they will not be processed nor will a response file be issued during this period.


Malta Extends FATCA Deadline

A notice has been issued by the Maltese Inland Revenue Department stating that they will be extending the previously established FATCA filing deadline of April 30, 2016 by one month to May 31, 2016.


France Releases Updated Guidance Notes

France recently released Guidance Notes version 2.2. Version 2.2 contains additional details regarding the encoding of files. Specifically, it clarifies that files not encoded in UTF-8 or UTF-8 with BOM will be rejected. Additionally, it clarifies that the presence of the tag defining coding is essential.  Files will be rejected if the tag is missing, incomplete, or incorrect.


Jamaica Releases FATCA News Update Concerning the 2016 Filing Deadline

The Jamaican Tax Administration has released an article reminding reporting financial institutions of the upcoming filing deadline on May 31, 2016 for all 2015 FATCA reports. The Tax Administration has not released any new filing information; rather, the article provides an overview of some of the key submission guidelines, and it provides contact information for any institutions that may need assistance.


Israel Ministry of Finance Rejects Stipulated FATCA Reporting Date

The United States and Israel had originally contemplated in their intergovernmental agreement that the first exchange of information would take place on September 30, 2016. Israel has released a notice rejecting that date due to the legislative complexities of implementing a reporting regime for relevant financial institutions.


Curacao, Israel, and Saint Lucia Signs Competent Authority Arrangement with the United States

The countries of Curacao Israel and Saint Lucia have recently signed Competent Authority Arrangement with the United States. The agreement’s purpose is to describe how each country’s tax authority will administer the FATCA reporting scheme, including the timing of the data exchange, and confidentiality agreements.


Hungary Releases Updated FATCA 2015 Guide

The Hungarian National Tax and Customs Administration has released a revised version of its guide for completing the 15FATCA Form. There is not any new significant information—but rather, some clarifications of points in the prior version:

  • The new version expounds upon the use of data services for submitting reports through the customer portal.
  • Incorrect, incomplete, late, or missing financial information may result in sanctions under Hungarian law.

The updated 15FATCA guide is available for download.


Colombia Releases Updated Corrections FAQs

Colombia recently released updated Correction FAQs. The new updates provide clarifications for Questions 6, 8, and 23. The updates include the following:

  • Question 6: Provided instructions on how to correct the GIIN error
  • Question 8: Provided clarification that if FATCAERRORRECORDGRP is not present, no corrections are needed for that report
  • Question 23: Added the new format for DocRefID and CorrDocRefID


Honduras issues Circular Outlining Upcoming FATCA-Related Reporting Dates

Honduras recently published Circular No. 7/2016 (dated April 6, 2016) which discusses FATCA reporting to occur in 2016. More specifically, the reporting of pre-existing accounts must occur by June 30, 2016. If a participating financial institution anticipates that it cannot complete review of pre-existing accounts by that time, said institution must inform the National Commission on Banking and Insurance by May 16, 2016 to enable financial module interconnection until June 30, 2016.


Denmark Releases Updated Version of FATCA Reporting Guidance

The Danish Ministry of Taxation has released Version 1.2 of its reporting guide for financial accounts, containing significant changes from the previous version of this document. The following notable updates should be recognized:

  • Self-Service Business: Reporting must be made via FTPS gateway—as was done last year—because the new platform will not be functional for the reporting deadline on May 1, 2016.
  • Identification Information: The guide contains specific instructions for formatting TIN numbers, addresses, country codes, and city names.
  • Reporting Amount: The guide contains specifications relative to formatting reported amounts and currency codes.
  • Nil Reports: Nil reports should be sent via e-mail, rather than on the FTPS gateway, to ekapital@skat.dk.
  • Test Reporting: Test reporting is done by forming a file with alerts sent to SKAT via the FTPS gateway’s test environment. The Gateway Guide also contains instructions relative to testing.
  • Response Files: The guide discusses the reporting system’s response files from SKAT and the IRS. Business validations will not be fully implemented into the system by this year’s reporting deadline.
  • XML Schema: Annex 12 (linked within the guide) contains the XML schema and a description of the format of response files.
  • Debug Instructions: The guide contains instructions regarding error messages. Note: An alert is approved only when a receipt is received from SKAT with an acceptance or error message from the IRS. If reports are submitted before the receipt is sent from SKAT, the entire file will be rejected.
  • Accessing Reporting Data: The reported data will eventually be available for view on the self-service business platform.


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