The guidance was released by email to parties registered on the Jersey AEOI portal on 2 June and is expected to be published shortly on the States of Jersey website. We have summarised below what we believe to be the key points arising from the guidance, however we would encourage all Financial Institutions to read carefully the guidance.
This note covers the following areas:
Extension to the UK IGA reporting deadline
Given that this is the first reporting deadline for the UK IGA, the Taxes Office appreciate that Reporting Financial Institutions may, for reasons outside their control, be unable to meet the reporting deadline of 30 June 2016. Accordingly, the Taxes Office will consider any reasoned requests for an extension to the reporting deadline in respect of the UK IGA up to Friday 29 July 2016. This is provided that the Reporting Financial Institution has registered on the AEOI portal by 30 June 2016. It is worth noting that the extension of the reporting deadline is in respect of the UK IGA only and that any reports required to be filed under the US IGA will be due by 30 June 2016.
Requests for an extension to the deadline should be directed to Niamh Moylan, Director of International Tax, by 30 June 2016 and should include an estimate of the likely size of the report in megabytes.
We would strongly recommend Jersey Reporting Financial Institutions to submit their reports as soon as possible in order to avoid any last minute technical issues.
Extension of deadline for due diligence procedures under the UK IGA
The Taxes Office has also announced that the deadline for completing due diligence procedures in respect of pre-existing lower value individual accounts and pre-existing entity accounts is extended from 30 June 2016 to 31 December 2016. This follows a similar extension to the due diligence deadline in the UK for UK Financial Institutions. The deadline for reporting in respect of the above accounts will remain 30 June 2017 provided that the Reporting Financial Institution carried out their due diligence on these accounts after 1 January 2016. An updated version of the IGA guidance notes will be issued shortly to reflect the above.
Update of the Jersey AEOI online portal
The changes to the AEOI online portal announced in the previous practical guidance released on 18 May are now live and allows for reports made under the Alternative Reporting Regime (“ARR”) in respect of the UK non-domiciled individuals to be submitted on the online portal.
The Taxes Office will shortly publish a document on the States of Jersey website listing common errors identified in reports submitted under 2014 US FATCA and provide guidance on how to avoid such errors for reports to be submitted for the current reporting periods.
How we can help
We have a dedicated Island team to provide assistance on any aspects of the submission process, including conversion and validation of reporting information in order to facilitate online filing on the Jersey AEOI portal.