Weekly FATCA Update: June 11-June 17, 2016

June 17, 2016

This week’s global update focuses primarily on FATCA with one CDOT press release and alternative reporting regime template change announced by the HRMC for Bermuda. Check out the compilation this week from our expert research team. (Btw, last week’s rumblings about the IRS changing the withholding requirement deadline was just that, a rumor.)


Slovenia Publishes FATCA Reporting Changes for 2015 Information (Version 3)

Slovenia has revised its FATCA update publication in order to incorporate additional changes in reporting procedures.

The new publication gives further detail regarding the format of the values to be entered into the and elements. Additionally, it provides the format for ‘Sponsoring Entity’ and ‘Fund’ type GIINs for use in the XML transmittal.


Bulgaria Launches New E-Service for FATCA Reporting

Bulgaria has launched a new service allowing for the submission of FATCA information. The service is available to those with “full” access and is designed for entities with active registration and qualified electronic signatures (QES) or persons authorized by them. Data submitted using this service should be submitted in an XML format.

To view the press release about the new e-service, please click here.


Slovenia Issues Revised Technical Protocols for FATCA

Slovenia has released an updated version (v1.6) of its technical protocols for FATCA submission. Filers should take note of the following changes and additional information:

  • Schema Guidance
    • Substantial Owners must always have a completed <TIN> element.
    • For instances in which a TIN cannot be obtained, ‘000000000’ is an allowable value for the <TIN> element.
    • The elements and must contain values that correspond to IRS specifications. These elements should contain the GIIN of the reporting Financial Institution and an alphanumerical value unique to the document, and they should not contain more than 200 characters. Failure to provide a unique value in the and will result in rejection of the FATCA transmittal.
    • The transmittal can contain the elements and when submitting Corrected Data (FATCA2), Void Data (FATCA3), or Amended Data (FATCA4). Corrected data must relate to data submitted for the same financial year. These elements should not be included in a New Data submission.
    • Each transmittal can only contain one type of reporting (New Data, Corrected Data, Void Data, or Amended Data). The XML guidance contains rules and procedures for the circumstances in which to use each of these document type indicators.
    • If the transmittal does not pass validation by Slovenia, the Financial Institution must submit a new file.
  • Error Resolution
    • If the contents of the FATCA transmittal are incorrect, the filer will receive an FVN file with a list of errors.
    • A legend for the error report elements and format is available in the guidance.
    • The user registration server certificate is available on eDavki in the Technical Information section of the PARS website.
    • If a Sponsoring Entity is reporting on behalf of a Financial Institution, it must obtain the Sponsoring Entity’s GIIN, which should have the characters ‘SP’ contained therein. If the ReportingFI element contains an ‘SF’ GIIN type, then the Sponsor element must be completed.
    • Financial Institutions must wait for IRS confirmation of receipt before sending additional files relating to the original.
    • Please follow the link provided below to access the revised Technical Protocols.


Malaysia Delays FATCA Reporting Until Next Year

The Lembaga Hasil Dalam Negeri Malaysia (LHDNM) has announced that it has deferred 2016 reporting to June 30, 2017.  By that date, information will need to be filed for years 2014, 2015, and 2016.  Malaysia’s IGA with the United States is not finalized.  As such, Malaysia’s status is considered “In-Substance,” and therefore, there is no requirement for Malaysia to submit information to the United States for this year.

To read about the announcement, please click here.


HMRC Publishes Template for Alternative Reporting Regime for Bermuda

The HMRC has published a press release and template for an Alternative Reporting Regime (ARR) to be used by Bermuda Financial Institutions (FI) for CDOT reporting. Bermudan FIs using the ARR must report directly to the United Kingdom rather than via the competent authority.

Where an ARR election has been made, any Specified UK Person wishing to take advantage of the ARR must provide the Bermudan FI with the information required by February 28 following the end of the relevant tax year.

As a reminder, the ARR enables an FI to elect to the competent authority in its jurisdiction to restrict reports of accounts that:

  • Are identified as held by Specified UK persons who are individuals, and who have non-domiciled status for UK tax purposes
  • Have elected for the remittance basis to apply

Additionally, where the conditions for the ARR are met Bermudan FIs need to report for all Specified UK Persons (who are individuals), name, address, date of birth and the gross payments:

  • And movements of assets from an originating UK source into the UK reportable account
  • And movements of assets from an originating source territory or jurisdiction that cannot be determined, into the UK reportable account during the relevant tax year
  • From the UK reportable account to an ultimate UK destination, during the relevant tax year
  • From the UK reportable account to an ultimate territory or jurisdiction that cannot be determined, during the relevant tax year


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