On 11 April 2017, the Government of Bermuda released the Common Reporting Standard Guidance Notes (Link) to provide assistance to financial institutions in Bermuda with the implementation of CRS. The draft guidance notes also include sample entity and individual self-certification forms. Within the document, the CRS reporting deadline is stated as 30 August 2017 and will follow the OECD’s CRS reporting schema (Link). The first notification due date for CRS in Bermuda is 14 July 2017, with subsequent notifications due by 30 April. Notification is a one-off process and does not need to be repeated annually. The guidance states that changes to notification details must, however, be advised to the Authority via the Electronic Portal. Subsequent reporting is expected to be due by 31 May and must be performed via the Electronic Portal. In addition, a user guide for the electronic portal will be issued to support Bermuda Reporting Financial Institutions with the processes of notification and reporting via the portal.
Finally, nil returns, as stated in the guidance, will not be mandatory, but institutions do have the choice to submit nil returns via the Bermuda Electronic Portal.
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