AEOI Updates: Jan. 21 – Feb. 3

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:

Several Countries Sign Model 1 IGAs

Anguilla, Greece and Greenland each signed IGAs this past week. Anguilla’s and Greenland’s IGAs are non-reciprocal — Model 1B — while Greece signed a reciprocal IGA — Model 1A. Anguilla will require financial institutions to either file electronically by using the IRS’ 5124 schema, or by filing manually on its AEOI portal. Greece and Greenland have not yet released guidance on this front. The Treasury’s initiative to have all remaining in-substance IGAs and entered into force means more countries will likely sign IGAs in coming months.

Denmark Publishes CRS Reporting Guidance and Technical Instruction

The Danish Tax Authority (SKAT) published guidance and technical instructions for financial institutions to follow when submitting XML reports to Denmark under the Common Reporting Standard (CRS).This guidance supplements the CRS Implementation Handbook and the CRS’ Annex 3. Danish financial institutions should use the CRS XML Schema for their transmittals and follow the instructions. This guide contains some restrictions and validations that do not exist in the OECD guidance. As a reminder, reporting to the testing environment opens on March 1. Reporting to the production environment opens on April 1 and closes by May 1.

Luxembourg Releases FATCA Schema Guide

Luxembourg published its schema guide for FATCA returns. As was the case with last year’s release, the new guide is available in an online newsletter (Newsletter du 19 Janvier 2017) containing several documents that assist in XML creation. As of now, Luxembourg has not published any similar documents for CRS or released any schema files.

Croatia Updates Instructions and Sends FATCA Notice to Financial Institutions

The Croatian Tax Administration updated its FATCA instructions on the Ministry of Finance’s website to remind financial institutions that they must use the new version of the FATCA XML Schema (v2.0) and the accompanying User Guide. Croatia will no longer accept files formatted according to the XML Schema v1.1.

Reporting financial institutions in Croatia must make their transmittals to the Tax Administration no later than June 30, 2017 for information relative to Tax Years 2014, 2015 and 2016. Financial Institutions must also ensure they have registered with the IRS for a GIIN before filing. The online filing portal through which Financial Institutions will submit their filings will be available for use at some point in the coming months. As of now, it is only available in a test environment.