Barbados is expected to defer initial CRS reporting to 2018

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).

The Cayman Islands Portal is back online and AEOI Portal User Guide v3.2 released

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.

Cyprus announces updates related to CRS reporting

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.

Cyprus announces updates related to FATCA reporting

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.

IRS issues corrections to the FATCA Regulations

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.