FATCA and CRS Alert issue 2016-01

FATCA and CRS Alert issue 2016-01

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OECD: Response to EU request, more “CRS XML schema” fields

The Organisation for Economic Co-operation and Development (OECD) announced that it has responded to a request from the European Commission to include additional fields in the common reporting standard (CRS) XML schema.

The EC request was made so as to further the work of the European Commission and the EU Member States on implementing a standard for the automatic exchange of financial information in tax matters within the European Union.

According to the OECD release, the agreed course of action includes a plan for adopting future changes to the CRS XML Schema, with a goal of a single global standard.

 

KPMG observation

Although the additional fields will only be required as from 2019 (given the nature of the additional fields), the fact that they may be required at all presents financial institutions with some difficult questions that need to be considered now, including:

  • Are amendments needed to their self-certification forms?
  • Are changes needed to their data collation and processing systems?
  • Are related controls and procedures also affected (to take into account these developments)?
  • Finally, if such changes are needed, when to make them?

Currently, there are no amending regulations that would give effect to the proposals.

Financial institutions could consider capturing some of the information required under the new fields as of the effective date of the CRS; this could avoid a situation of requiring them to capture the information retroactively. However, until there is certainty and clarity as to the extent and timing of the proposals, financial institutions could be reluctant to make changes to their current CRS programs in the short term.

 

For further information, please do not hesitate to contact us.

 

 

 

 

 

 

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.
 

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