On 28 June 2017, PwC’s CITT Compare Tool was updated to include the latest content from Austria, Belgium, Gibraltar, Guernsey, and Singapore and to reflect the latest signatories to the MCAA. Please take this opportunity to re-run reports for those countries and use the latest information within your projects.
The Barbados Revenue Authority (“BRA”) has recently communicated its decision to commence exchanging information in accordance with the International Standard on Automatic Exchange of Financial Information (Common Reporting Standard or “CRS”) by September 2018 instead of the initial reporting year of 2017. This is expected to be reflected in the next OECD signatories list (Link).
The BRA has encouraged all financial institutions to ensure that they have the necessary framework in place to meet their reporting obligations when they become due and has advised that they will release further information in due course.
For FATCA, all reporting Financial Institutions in Barbados are required to register (Link).
On 23 June 2017, the Service Public Fédéral Finances (“SPF Finance”) in Belgium announced (Link-French) that reporting for CRS purposes will be extraordinarily extended to 31 July 2017 for 2016 reportable accounts. It should be noted that FATCA Reporting continues to be due on the original deadline of 30 June 2017.
On 16 June 2017, the British Virgin Islands Ministry of Finance issued an updated version of the BVI Financial Account Reporting System User Guide (Link) to include information regarding CRS submissions.
On 28 June 2017, the Cayman Islands Department of International Tax Cooperation (DITC) published an updated AEOI Portal User Guide v3.2 (Link). In addition, the DITC reminded users that they must review the AEOI Portal User Guide Prior to preparing and submitting CRS returns. Finally, users are reminded that the Cayman Islands Automatic Exchange of Information Portal is back online and report submissions for FATCA and CRS can be completed.
On 23 June 2017, the South African Revenue Service (“SARS”) released an updated Status Summary of all Tax Information Exchange Agreements (Bilateral) (Link) on the SARS homepage. In addition, the Status Summary of all CRS CAAs (Link) can be found on this page.
On 22 June 2017, the Cyprus Tax Department issued an announcement (Link) that Cyprus financial institutions with no CRS reportable accounts for 2016 are not required to register with the Government Gateway Portal and the respective FATCA/CRS/DAC2 e-service. Financial institutions that have already registered but have no CRS reportable accounts for 2016 can either submit a sample Nil Report or request to deactivate from the CRS e-service.
On 21 June 2017, the Cyprus Tax Department issued an announcement (Link) that Cyprus financial institutions with no FATCA reportable accounts for 2016 are not required to register with the Government Gateway Portal and the respective FATCA/CRS/DAC2 e-service. Financial institutions that have already registered but have no FATCA reportable accounts for 2016 can either submit a sample Nil Report or request to deactivate from the FATCA e-service.
On 29 June 2017, Bahrain was added to the OECD’s CRS Multilateral Competent Authority Agreement signatories list, raising the number of signatories to 93 (Link).
On 30 June 2017, the U.S. Internal Revenue Service (“IRS”) issued a correcting amendment to the final and temporary FATCA implementation regulations (Link) to align the curing procedures for hold mail instructions to the chapter 3 requirement. The correction would require that the account holder provide documentary evidence to establish residency in the country in which he or she claims to be a tax resident. Previously, the requirement was simpler, requiring the account holder to provide evidence of non-U.S. status. In this way, the chapter 4 regulations have been aligned to the chapter 3 requirement, whereas many in the industry were hopeful of the opposite outcome.