AEOI Updates: March 25 – April 7

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:

Cayman Island Publishes List of Reportable Jurisdictions, Updates Participating Jurisdictions

The Tax Information Authority for the Cayman Islands has published its list of Reportable Jurisdictions in the Cayman Islands Gazette (beginning on page 15).  This list informs reporting financial institutions of the foreign account holders they must report. In addition, the Cayman Islands updated its list of Participating Jurisdictions.

Singapore Amends CRS Regulations

New regulations came into effect this week for the CRS in Singapore, as the Minister for Finance published an amendment to last year’s regulations. Many of the amendments concern due diligence procedures, including the self-certification process.  Singapore is a late adopter.  Financial Institutions are required to complete the due diligence procedures this year, and then report in 2018.

British Virgin Islands Reminds Financial Institutions of Reporting Obligations and Extends CRS Deadlines

The BVI International Tax Authority relaxed the statutory deadlines for both U.K. CDOT and CRS, extending them to June 30, 2017 for enrollment and to July 31, 2017 for submissions. The ITA will inform BVI financial institutions directly once the portal is open to accept UK and CRS enrollments and filings. In addition, U.K. CDOT is currently in transition to being subsumed within CRS. BVI financial institutions should submit the maximum of what is required by CRS or UK CDOT to be fully compliant. Those with U.K. CDOT obligations should submit using the manual entry or upload option via the CRS filing option.

As for FATCA, the ITA has announced the BVI Financial Account Reporting System (BVIFARS) is now open and prepared to accept FATCA returns for Tax Year 2016. Financial institutions that were not previously registered with BVIFARS must haved enrolled to file by April 1, 2017. The due date for all filings will be May 31 – which will not be subject to extension by the BVI government.

Luxembourg Releases Reportable Jurisdictions

Luxembourg has published its list of Reportable Jurisdictions in the Journal Officiel. This document is Luxembourg’s first such publication. The list is a requirement from the CRS, and should be used by reporting financial institutions with reportable accounts. Otherwise, an FI may submit a Nil but it is not required to do so.

OECD Releases Second Edition of CRS Guidance

The OECD recently released a new edition of the Standard for Automatic Exchange of Financial Account Information, sometimes referred to as the “purple book.” The OECD explains the update was made to give more clarity to the process of submitting corrected returns. In that vein, the OECD updated the information in the Common Reporting Standard User Guide, or the XML User Guide, contained in Annex 3. The Annex begins on page 230.