Bermuda CRS Deadlines Extended and Reminders!

On April 28, 2022, the Bermuda Ministry of Finance (the Ministry) published a notice of extended CRS deadlines and other reminders. Due to technical maintenance on the Bermuda Tax Information Reporting Portal (the Portal), the Ministry extended deadlines for Common Reporting Standard (CRS) registration and reporting.

  • The CRS registration deadline for newly formed Reporting Financial Institutions for the 2021 reporting period is now May 31, 2022 (extended from April 30, 2022).

  • The CRS reporting deadline for 2021 CRS filings is now June 15, 2022 (extended from May 31, 2022).

The Ministry also provided the following reminders:

  • Reporting entities must confirm that there is an active and Primary User that can be contacted at all times. They should submit a Primary User Change Notice as soon as they become aware that a Primary User can no longer act in this role.

  • Reporting entities that no longer have reporting obligations must request to be deactivated from the portal as soon as possible. Deactivation requests cannot be processed until all relevant filings are exchanged with partner jurisdictions.

  • The CRS requirements of the OECD allow accounts to be treated as undocumented in specific circumstances. See subparagraphs B(5) and C(5) of Section III of the CRS. Reporting Financial Institutions (FIs) should not report accounts as undocumented in any other circumstances and they must follow the CRS due diligence rules to determine the treatment of accounts that do not meet the outlined criteria.

  • The Taxpayer Identification Number (TIN) field for account holders and controlling persons reflects as an optional field. This does not mean that it is optional to provide the information. Reporting FIs must confirm that they include TINs in their reports that are in line with the due diligence requirements outlined in the CRS - including the requirement to use reasonable efforts to obtain TINs of preexisting accounts that are not already in the FIs records. Failure to do so may result in an error notification from the Ministry or a partner jurisdiction that requires correction and potential compliance reviews.

  • The Date of Birth Field for individual account holders and controlling persons also reflects as optional, which does not mean that it is optional to provide this information. Reporting FIs must confirm that they include dates of birth where required. The Ministry expects dates of birth to be submitted for all individuals and controlling persons and will notify reporting FIs where this is not the case.

  • The Ministry expects that reporting FIs include full addresses for all account holders where available in their systems or in the account holder documentation and self-certifications, even though only the city and country fields reflect as mandatory in the OECD CRS XML schema.

  • All Bermuda FIs should review the OECD list of potential high-risk CBI/RBI schemes that can be used to misrepresent an individual's jurisdiction(s) of tax residence and determine the effective implementation of the CRS due diligence procedures. For additional details from the OECD, please see this link: https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/residence-citizenship-by-investment/

Check out the Ministry of Bermuda notice here:

https://www.gov.bm/common-reporting-standard-country-country-reporting


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