Countries all over keep taking steps to ensure they are on track to fully participate in CDOT and CRS. Here are the weekly CRS updates compiled by our tireless research team.
British Virgin Islands Opens Portal for UK CDOT Filings and Issues Revised BVIFARS User Guide with CDOT-Specific Updates
The British Virgin Islands has announced the opening of its UK CDOT (i.e. UK FATCA) portal for online reporting of financial accounts held by British citizens in BVI. Filers can access the enrollment function and log in to their accounts to begin the reporting process. As a reminder, the filing due date for reporting years 2014 and 2015 has been extended to July 29, 2016. The Ministry of Finance of the British Virgin Islands has updated its BVIFARS User Guide in order to provide further functional guidance and to introduce CDOT filing instructions as well as updates to previous FATCA guidelines. This revision (Version 4.0) contains major substantive additions to the prior version of the User Guide that should be noted, including:
- Enrollment instructions: Users should only submit one enrollment form to obtain credentials, and use the Change of Reporting Obligations form to update CDOT information if necessary.
- Identification numbers: Institutions filing information for CDOT reporting should use their prior-obtained GIIN for enrolling—if no GIIN exists, then the institution will be assigned a Financial Institution Reference, to be used solely for CDOT reporting.
- Local Address: For FATCA only, Sponsoring Entities are permitted to have a non-BVI address. In all other cases for FATCA and CDOT, the BVI Registered Office Address must be local.
- New Password Reset Directions.
- Changes in Reporting Obligations: Institutions undertaking FATCA and/or CDOT reporting have an obligation to notify BVI of any changes in their reporting obligations (including changes in reportable jurisdictions) using the Change of Reporting Obligations form.
- Multiple BVIFARS Users: Primary Users for financial institutions and those reporting on their behalf may designate and deactivate other users for their BVIFARS accounts. Secondary Users will have the same permissions as Primary Users except the authority to designate other users.
- Reviewing Submitted Files: Users will have the ability to review submitted filings at any time. XML Upload filings will be available for download. In order to amend any filings, users should submit a separate filing designated “Corrected,” “Amended,” or “Void” as the document type.
- Annual Submission Fee Filing: Although users will see an Annual Submission Fee Filing present on the Create Filing page, this should be disregarded until further instruction.
- Document Types: Users should make separate filings for each document type (New, Corrected, Amended, or Void).
- Document Reference IDs: Users should take note of the new Document Reference ID format required by the IRS and HMRC. The DocRefID must be completed for each applicable section, but the “unique value” should be different for each section.
- Reporting Payments: If the financial institution has any payments to report on the account, it must complete all three sections for recording payments. If there are not any reportable payments on the account, user must delete the payment record.
- CDOT-Specific Updates: The CDOT filing procedures are generally the same as those for FATCA, with the following exceptions—
- For the Message Reference field, BVI recommends using a GIIN or BVI FI Reference Number in combination with a GUID.
- The Account Holder Type field makes reference to US persons or US owners. For purposes of CDOT filing, these should be interpreted as UK persons and UK owners.
- Pooled Reports are not used for CDOT filing.
Cayman Islands Issues CRS Guidance
The Cayman Islands, an early adopter of the Common Reporting Standard (CRS), has issued guidance. The Caymans will begin reporting next year, with a due date of May 31, 2017. The reporting schema to be used will be the CRS XML schema provided by the OECD. The filing of Nil Reports will not be mandatory; however, Cayman Financial Institutions are permitted to submit Nil Reports through the AEOI portal if they so choose.
UK Releases New Information Manual
The UK has recently released a new version of its AEOI information manual. While the information manual is intended to be used by the HMRC staff, it’s information is very useful for UK Financial Institutions. The new manual focuses on CRS, but it does contain distinctions for both FATCA and CDOT reporting. As of now, the manual is only available in HTML format, though HRMC is expected to release a pdf version shortly.
Finland Passes CRS Legislation
Finland recently passed CRS Legislation. They amended § 17 of the Tax Procedures Act to include due diligence and reporting under the CRS scheme. The amendment was entered into force as of April 15, 2016. The Tax Administration will issue further tax provisions for CRS, including provisions on the due diligence procedures and information to report. § 17 of the Tax Procedures Act also covers FATCA reporting.
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