The Dutch government has issued guidance on the Dutch FATCA and CRS reporting for the calendar year 2017. For easy reference, we have provided an overview of the guidance below. The guidance contains the preliminary country list of reportable countries for 2017 reporting, the updated reporting manuals for reportable years 2017 and 2018 the deadlines for the FATCA and CRS reporting.
Reporting deadlines, registration procedures and letters sent by the Dutch Tax Authorities
In October, the Dutch tax authorities published the 2018 reporting deadlines in the Netherlands. The statutory reporting deadline is 31 January annually. However, in line with last year the Dutch tax authorities have provided extended deadlines. A generic extension to 6 February 2018, for Financial Institutions that have a domestic information reporting obligation, and a prolonged extension for payments and savings products under the Dutch domestic information reporting rules to 30 April 2018. Financial Institutions that solely have a FATCA and/or CRS reporting obligation have to ultimately submit on 1 August 2017, although it is advised to submit in an earlier stage.
Dutch Financial Institutions that have not yet reported under FATCA or CRS in a previous year, are required to register themselves with the Dutch tax authorities prior to submitting the report (generally, a few days are required to process the registration). The Dutch tax authorities will not accept the FATCA and/or CRS reports without upfront registration. Financial Institutions can register via the following link: https://www.gegevensportaal.net/fatca/aanmelden/. Financial Institutions need to indicate in the portal whether they will report under FATCA, CRS or both and the total number of accounts to be reported.
Dutch Financial Institutions, that reported under FATCA last year, may have – in line with last year – received a letter from the Dutch tax authorities in which they are requested to provide an indication of the number of reportable accounts.
The 2017 CRS reporting deviates from the 2016 reporting in the following aspects:
- The CRS report over 2017 requires to report on tax residents in 106 jurisdictions (see the attached list for a full overview of reportable jurisdictions). For reference purposes, the number of reportable jurisdictions for the reportable year 2016 was 46;
- Please note that the pre-existing account review deadline in the Netherlands is 31 December 2017. As such all financial account holders will need to be reviewed by year end.
Although Financial Institutions have already reported under FATCA during 2015 to 2017, reporting will deviate from earlier filings. The main change in FATCA reporting is:
- Reporting on NPFFIs is no longer required
Dutch reporting schema
The FATCA and CRS reports can be submitted together in one file. The Dutch reporting schema for FATCA and CRS deviates from both the standard 8966 FATCA reporting schema as well as the CRS XML reporting schema issued by the OECD. Therefore, Dutch Financial Institutions are encouraged to assess if they are capable to report in accordance with the Dutch reporting schema.
The Dutch reporting schema requirements have been published in manuals on cggp.nl (please note that registration is required to be able to download the manuals). The manuals are only available in Dutch. Please note that compared to last years template a new field was added to the report (indication undocumented).
In order to be able to submit the reports (in the requested Dutch XML format), Financial Institutions also need to make sure that a digital connection with the Dutch tax authorities is established.
How can PwC assist you
PwC has created a front to end FATCA and CRS reporting solution. We can assist with
- Assessing whether reporting for FATCA and/or CRS is required in the Netherlands;
- Registering Financial Institutions with the Dutch Tax Authorities in the Netherlands in case there is a reporting obligation;
- Creating the xml-file and submit these via our secure portal to the Dutch tax authorities. The report together with the full trail of submission will remain accessible at all times.
In addition to the reporting solution, PwC can provide assistance with data extraction and filtering and any other questions around reporting or generically on FATCA and CRS.
Should you have any questions or want to know more about the reporting solution, please contact your PwC contact or any of the experts mentioned below.
Remco van der Linden
Tel: +31 (0)88 792 74 85 | Mobile: +31 (0)6 20 40 22 91 | firstname.lastname@example.org
Tel: +31 (0)88 792 76 10 | Mobile: +31 (0)6 23 83 70 43 | email@example.com
Tel: +31 (0)88 792 72 95 | Mobiel: +31(0)6 21 51 86 81 | firstname.lastname@example.org
Robert Jan Meindersma
Tel: +31 (0)88 792 61 86 | Mobile: +31 (0)6 83 60 84 41 | email@example.com