The Organisation for Economic Co-operation and Development (OECD) announced that the OECD 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.
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 whether amendments are needed to their self-certification forms and whether changes are needed to their data collation and processing systems, and related controls and procedures (to take into account these developments) and 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 the financial institutions 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.
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