The world keeps spinning and countries keep taking steps to ensure they are on track to fully participate in FATCA. Here are the weekly FATCA updates from different countries across the globe compiled and presented for you to stay in the know when it comes to AEOI and global reporting.
Slovak Republic Releases Competent Authority Arrangement as well as v. 3.6 FATCA Schema and Guidance
The Slovak Republic has published its Competent Authority Arrangement with the United States. The Arrangement’s purpose is to describe how each country’s tax authority will administer the FATCA reporting scheme, including the timing of the data exchange, and confidentiality agreements. The Slovak Republic also released a new version of their FATCA schema v. 3.6, along with guidance for said schema and for registering Global Intermediary Identifying Numbers (GIIN). To see these updated documents, please visit the country’s financial administration FATCA page and look at the bottom for the list. As a reminder, registration must occur by May 31, 2016 and reporting must be completed by June 30, 2016.
Panama Signs IGA to Implement FATCA Reporting
On April 27, 2016, Panama and the United States signed an Intergovernmental Agreement (IGA) to implement FATCA reporting in Panama. It had been previously agreed to in substance and treated as if it were in effect. Both countries have agreed to a Model 1A IGA. The Treasury updated its IGA list to include Panama on April 28, 2016. To see the announcement from Panama’s Ministry of Finance, please click here.
Brazil Releases Updated FATCA Filing Manual
Brazil has released an updated FATCA filing manual and there are a few notable changes from the previous revision:
- The change of the hash algorithm from SHA-1 to SHA-2 in signature events (Items 2.2.6 and 2.2.8 of the Manual)
- Clarifications on the generation of delivery receipt numbers (Item 2.1.2.1)
- Validation Rule Update (Items 3.3.1.20-22)
- REGRA_VALIDA_FORMATO_MASCARA_GIIN, including new codes (SF, SD, SS and SB) adopted by the IRS for GIIN registration purposes
- Updates regarding accumulated payments for Tax Year 2015
- The first month of the sample code in Item 4.1.3.1.80 has been fixed
- New guidelines on the inclusion of rental reports of titles and securities and the declared Relationship Type field
Click here to access all of the changes in total and to see the updated FATCA filing manual.
New Zealand Updates Inland Revenue User Guide
New Zealand has updated its Inland Revenue User Guide and are a few updates from the previous revision:
- The instructions for notifications have changed to say that the IRS will directly send a filer a notification through the International Data Exchange Portal (IDEP) once the filer’s disclosure has been received by the IRS. This disclosure will say whether the disclosure has been accepted by the IRS, and if so, whether there are any errors within it that need to be corrected.
- A section was added on how to view notifications on IDEP.
- A section on understanding IRS notifications was added to the Revenue User Guide.
- Rejection messages are now split up by Rejected message type and have a greater explanation of why the rejection message may have been received.
- Section 6 is no longer Notifications. It is now Submission History.
- Conversely, Section 7 is now Notifications instead of Submission History.
Norway Releases New Update Contact Form
Norway has released a new electronic update contact form (Form RF-1312). This form is used for the enrollment, withdrawal, and change of contact information with Norway’s Tax Administration. Any change of contact details (i.e. name, telephone number, contact person, etc.) must be reported via Altinn, Norway’s public reporting portal. In order to fill out the form, filers must have an Altinn account contact already.
British Virgin Islands Issues Revised BVIFARS User Guide for FATCA
The Ministry of Finance of the British Virgin Islands has updated its BVIFARS User Guide in order to provide further functional guidance for FATCA and to introduce CDOT filing instructions. [link to new CRS update) 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.
- FATCA-Specific Updates
- Document Reference IDs: The Reporting FI GIIN within the DocRefID must match the GIIN entered in the Reporting FI TIN field on its information form or the TIN within the Reporting FI group.
- IRS Notifications: Once BVI submits filings to the IRS, the IRS will notify financial institutions via e-mail for any corrections that may be required. In order to view the notification, users must log-in to BVIFARS and view the referenced submission. Corrections should be submitted via BVIFARS. Failure to correct within 120 days of the notification will result in a determination of non-compliance.
- Note: For 2014 reporting, notifications concerning absence of TIN or Date of Birth may be ignored. For 2015 reporting, either the TIN or Date of Birth are necessary. For 2016 reporting, TIN is mandatory.
- Submitting Corrected Filings: Be sure to include the proper Document Type, and the corresponding Message Reference ID and DocRefID. The corrected file must have sufficient data from the original file to pass schema validation. If the error is in the Financial Institution’s GIIN, a user should submit a void filing then a New Data filing with the correct GIIN. Additionally, New Data filings should be used for Invalid Message Ref ID, Duplicate Message Ref ID, and Invalid Doc Ref ID.
- Account Holder Type: For Individual account holders, user must not make a selection for Account Holder Type within the Account Report form; however, it is required if the Account Holder is an entity.
- Pooled Reports: The Pooled Reporting Type form is not intended for use in Model 1 jurisdictions.
- Account Numbers: For cases in which user does not have an account number for a reported account, user should provide the “unique identifier used by the financial institution.” If no such unique identifier exists, then state “NANUM.”
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