The United Kingdom and its Crown Dependencies and Overseas Territories and others
The United Kingdom and its Crown Dependencies and Overseas Territories are all early adopters of the CRS, so for clients in those jurisdictions which were affected by UK FATCA, it is important to note that this is A “TRANSITION” YEAR which does impact the CRS due diligence and reporting obligations differently in those jurisdictions.
DID YOU KNOW AND ARE YOU READY
The first exchange of information about new accounts and pre-existing personal high-value accounts will take place by the end of September 2017.
TIMETABLE 2016 – 2017
The first group, currently of 54 jurisdictions, are running to an ambitious but realistic timetable as follows:-
Pre-existing accounts are those that were open on 31 December 2015 and new accounts are those opened from 1 January 2016 – SO new account opening procedures to record tax residence needed to be in place from 1 January 2016.
The due diligence procedures for identifying:
- HIGH-VALUE PRE-EXISTING individual accounts will be required to be completed by 31 December 2016,
- LOW-VALUE PRE-EXISTING individual accounts and entity accounts will be required to be completed by 31 December 2017.
The first exchange of information about new accounts and pre-existing personal high-value accounts will take place by the end of September 2017.
Information about pre-existing personal low-value accounts and entity accounts will either first, be exchanged by the end of September 2017 or September 2018 – depending on when financial institutions identify them as reportable accounts.
Full details of the Common Reporting Standard, surrounding commentary, and the supporting agreement (Competent Authority Agreement “CAA”) and more useful material can be found here: http://bit.ly/2bElo7J
Loading...