On 31 March 2017, the Cayman Islands Gazette (Link) was issued to include (1) the list of CRS Reportable Jurisdictions (for reports due in 2017 and onwards) on page 15 as well as (2) the list of CRS Participating Jurisdictions on pages 16 and 17.
On 18 April 2017, the Cayman Department for International Tax Cooperation released an update (Link) followed by an Industry Advisory on 13 April 2017, which include the following updates:
- The AEOI Portal will be offline until “the beginning of May” due to software upgrades and updates for CRS notifications.
On 12 April 2017, the Cayman Islands Ministry of Financial Services issued an Industry Advisory (Link) stating that the Department for International Tax Cooperation (“DITC”) issued the Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters Guidance Notes Version 2.0 (Link).
In addition, an updated Self-Certification Form for entity account holders (Link) was also circulated for industry use.
On 4 April 2017 and 10 April 2017, the Singapore authorities issued amendments to the Singapore Common Reporting Standard (“CRS”) Regulations (Link) and updates to the Inland Revenue Authority of Singapore (“IRAS”) CRS FAQs (Link) respectively. Updates were made to FAQs C.13, E.21 and E.22. In addition, a CRS brochure (Link) was released by the IRAS which is intended to assist account holders in understanding CRS.
PwC Singapore has prepared a summary which provides a brief overview of how these changes to the CRS regulations and updated FAQs may impact financial institutions in Singapore in its latest Tax Bulletin.
On 10 April 2017, the Inland Revenue Authority of Singapore (“IRAS”) announced (Link) that it has concluded a bilateral Competent Authority Agreement (“CAA”) with Guernsey (Link) for the automatic exchange of financial account information. Under the CAA, the IRAS will automatically exchange financial information of accounts in Singapore held by tax residents of Guernsey with the competent authorities of Guernsey for reciprocal information.
This brings the total number of CAAs which have been signed up to 22. The first submission by Singapore FIs is scheduled for 31 May 2018 under all existing CAAs with the first exchange between governments occurring by September 2018.
On 19 April 2017, the State Bank of Pakistan issued a Circular (Link) reminding financial institutions that Pakistan has signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and that it has finalized the CRS Rules on 15 March 2017 (Link). Finally, financial institutions were reminded that they should begin due diligence of customers as of 1 July 2017.
The Inland Revenue Division of the Government of Grenada has announced (Link) that implementation of the FATCA IGA with the United States which was signed on 29 November 2016, is “now a formality”.
On 30 March 2017, Brazil reopened its so-called Special Regime of Exchange and Tax Regularization (“Regime Especial de Regularização Cambial e Tributária or “Rerct”) which was announced on 3 April 2017 (Link-Portuguese). This newly opened amnesty includes a 135% penalty on the tax due.
In our latest alert, with regard to the British Virgin Islands (“BVI”), we stated that “…the ITA has decided to extend both the UK CDOT and CRS deadlines to 30 June 2017.”
In fact, the International Tax Authority (“ITA”) in the BVI has extended the reporting deadline for CRS and UK CDOT to 31 July 2017 and the enrolment has been extended to 30 June 2017.
The Federal Central Tax Office (“Bundeszentralamt für Steuern” or “BZSt”) has sent an e-mail with the Subject: Guidance note on coordinated external tax audits with tax administrations of other states and jurisdictions (Link-German) (Link-English).
The 23 page guidance note provides principles which should apply with respect to the execution of coordinated external tax audits with tax administrations of other states and jurisdictions. The guidance note includes information on the legal basis for coordinated external tax audits within the EU and with third countries as well as joint external tax audits by the German tax administration. In addition, the guidance note provides practical direction on conducting coordinated audits.
On 1 March 2017, the German Ministry of Finance, in conjunction with the Federal Central Tax Office (“Bundeszentralamt für Steuern” or “BZSt”), sent an e-mail with the Subject: Automatic exchange of information under the Common Reporting Standard and the German implementing law – Publication of the official data schema (Link-German) which was also posted to its official website. The e-mail also contains information on the data submission channel to be used to submit reports for 2017 and subsequent years. Forms for individual and single data uploads will be available through the online portal of the BZSt.