Spain Publishes New CRS and FATCA FAQs

Tom Hospod
May 12, 2017

This blog was last updated on December 22, 2021

The Spanish Tax Administration has published additional answers to Frequently Asked Questions regarding FATCA and CRS reporting. The questions address specific circumstances – under both FATCA and CRS – in which a Financial Institution is obligated to carry out blocking of a financial account for both entities and natural persons:

  • A Financial Institution must block an account of an individual when the TIN is not included in a new account declaration. Additionally, the FI must communicate that the TIN is missing to the country or jurisdiction of tax residency that appears in the new account declaration.
  • For entity accounts, the mere absence of an active or passive determination does not require the FI to block the account.

The new FAQs also address the treatment of certain Spanish not-for-profit foundations and other tax-exempt entities for the purposes of CRS and FATCA.

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Author

Tom Hospod

Tom Hospod is a Regulatory Counsel at Sovos Compliance. Within Sovos’ Regulatory Analysis function, Tom focuses om Affordable Care Act (ACA) reporting, Tax Withholding, and Automatic Exchange of Information (AEOI). Prior to Sovos, Tom worked as a legislative aide in the Massachusetts House of Representatives. Tom is a member of the Massachusetts Bar, earned his B.A. from Boston College and his J.D. from the University of Miami.
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