AEOI Updates: March 10-24

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:

Germany Releases Infobriefs for FATCA & CRS

Germany released its first 2017 Infobriefs for FATCA and CRS. FACTA Infobrief 01/2017 discusses the use of the IRS’s version 2.0 XML schema, including the development of a new Communications Handbook. CRS Infobrief 01/2017 updates the list of participating jurisdictions and has information on registration requirements.

Isle of Man Amends CRS Regulations and Issues Advisory Notice

The Isle of Man issued Amendments to the 2016 CRS Regulations and provided an Advisory Notice to provide an explanation. The amendments offer further clarifications on issues such as excluded accounts and reportable accounts. The Advisory Notice also contains information on registration for both FATCA and CRS reporting, ARR reporting for CDOT, sending test files, and an updated list of Reportable Jurisdictions. As a reminder, both FATCA and CRS reports are due by June 30.

Belgium Releases CRS Guidance

Belgium’s FPS Finance has recently posted guidance for CRS due diligence and reporting, containing over 100 pages of instructions to help financial institutions ensure they remain compliant with the CRS. Reporting will begin June 30 and should be reviewed by all reporting Belgian financial institutions. CRS returns should be formatted per the specifications released by the OECD and FPS.  Moreover, nil returns are required to be filed by those financial institutions with no reportable accounts.

Belize Enacts CRS Legislation

Belize posted its CRS legislation to the OECD portal. The Mutual Administrative Assistance in Tax Matters of 2017 allows the Financial Secretary to be the competent authority in charge of implementing the CRS. In addition, the act indicates nil returns are mandatory, the due date will be March 31, and third-party service providers will be allowed. There are also several provisions on penalties, beginning in Section 20 on page 169. According to the OECD portal, Belize will use the CRS schema designed by the OECD.

IRS Updates its FATCA IDES Technical FAQs

On March 22, the IRS posted new FAQs to its FATCA IDES website. There are three questions: C28, C29, and C30. The new questions provide instructions on how to properly format the FilerCategory, AccountClosed, and AccountNumber fields. These FAQs should be reviewed to ensure filers produce compliant FATCA transmittals.