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Comply Connect – October 2023 – Issue 5

David Marley CEO

Comply Exchange is pleased to announce a strategic partnership with SAP Ariba, together working in collaboration with PayPal, a leading global payments platform. This marks the commencement of a groundbreaking alliance, united by a shared vision to transform, automate, and simplify the onboarding experience.

COMING UP IN November 2023:

COMING UP IN November 2023:

Comply attended and presented at the Comply Connect 2023 conference hosted by Sovos this month. We appreciate Sovos giving us the opportunity to present and attend, and for their partnership. Stay tuned for our Key Takeaways article!


Draft Forms W-9 and W-8EXP

As of the release of this month’s issue, the IRS has not finalized the Draft Forms W-9 and W-8EXP which have an October 2023 revision date.

On October 19, the IRS released draft Form W-8EXP instructions.

IRS Draft Forms and Instructions

During October, the IRS published the following DRAFT forms and instructions:

Form 1042-T

On October 10, the IRS published the 2023 version of the Form 1042-T, Annual Summary and Transmittal of Forms 1042-S. Only minor formatting updates were made to the form.

QI Deadline

On October 11, the IRS published a reminder that the deadline for all Qualified Intermediary’s (QI), including Qualified Derivatives Dealer (QDD), Withholding Foreign Partnership (WP), and Withholding Foreign Trust (WT) applications for the 2023 is October 27, 2023.


On October 30, the IRS issued two FAQs (Q23 and Q24) on the QI/WP/WT’s FAQs page under the section, Certifications and Periodic Reviews. These FAQs provide guidance on QIs making written solicitations requesting U.S. TINs of account holders holding interests in publicly traded partnerships through QIs.


IRS: Public Key for FATCA Reporting

On October 4, the IRS published Issue Number 2023-07 regarding expiration of the IRS Public Key. The IRS has a new key and replaced the existing key on Friday, October 13, 2023, at 11:59pm EST. After October 13, a new IRS Public Key needs to be downloaded from IDES to submit FATCA reports.

OECD: Updates to Tax Residency & Tax Identification Numbers

The OECD published updated information on Tax Identification Numbers and Tax Residency rules for various jurisdictions. Tax Identification Number information was modified for Armenia, Azerbaijan, and Belize. Tax Residency rules were modified for Azerbaijan and Belize.

Australia: Automatic Exchange of Information Guidance

On October 26, the Australian Taxation Office (ATO) updated its Automatic Exchange of Information Guidance – CRS and FATCA.

Bahamas: FATCA and CRS Deadlines

The Bahamas Competent Authority published a reminder of key dates for FATCA and CRS reporting. The AEOI portal opened on Tuesday, October 10, 2023, at 9am EST for AEOI registration and submissions, and will close on Wednesday, December 6, 2023, at 5pm EST.

Bahamas: CRS Reportable Jurisdictions

On October 10, the Bahamas Competent Authority published an updated list of CRS reportable jurisdictions.

Barbados: Guidance Note OGC No. 05/2023

On October 4, the Barbados Revenue Authority (BRA) issued Guidance Note OGC No. 05/2023. The guidance note informs all entities desiring to deregister from the AEOI Web Portal are required to visit the Global Relations Unit Web Portal and complete a deregistration form.

Switzerland: AEOI Partner States

On October 11, the Federal Tax Administration of Switzerland (FTA) updated its list of AEOI partner states.

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