Global Response to the COVID-19 Crisis for AEoI Reporting in the year 2020

Who is Impacted


Anyone with Automatic Exchange of Information (AEoI) filing requirements under the Foreign Account Tax Compliance Act (FATCA) or the Common Reporting Standard (CRS) will be interested in staying connected with updates from tax authorities in various jurisdictions, including the Internal Revenue Service (IRS), the Treasury Department, and Organization for Economic Cooperation and Development (OECD) to find new and changing information as a result of the global COVID-19 crisis.


What Changed


Over the last few weeks, a number of countries have published guidance regarding reporting in the year 2020. Due to the ongoing COVID-19 crisis, many have delayed the reporting dates for this year among other changes. Here are a few of note:


New May Deadlines


Singapore

FATCA and CRS Deadline: 31 May 2020. See FATCA Announcement and


Links:

CRS Reportable Jurisdictions

Inland Revenue Authority of Singapore Portal

FATCA eTax Guide

CRS eTax Guide

New June Deadlines


India

CRS Deadline: 30 June 2020. See Taxation and Other Laws (Relaxation of Certain Provisions)


Links:

Reporting Portal User Guide

India Reporting Portal


Malta

CRS and FATCA Deadline: 30 June 2020.


Links:

CRS Reportable Jurisdictions, see Appendix 1.

Malta Guidance Notes

New July Deadlines


Bermuda

CRS Deadline: 15 July 2020. See Government of Bermuda Website.


Links:

CRS Reportable Jurisdictions

CRS Guidance Notes

Bermuda Portal User Guide


France

FATCA and CRS Deadline: 31 July 2020

Rule Updates: The French Tax Administration published FAQs on its CRS self-certification.

Portal Updates: Portal will close on 3 August 2020.


Links:

CRS Technical Guidance

FATCA Technical Guidance


Malaysia

CRS Deadline: 31 July 2020. See Malaysia Portal.


Links:

CRS Reportable Jurisdictions

CRS Guidance Notes

CRS User Guide

FATCA Guidance

New August Deadlines


Russia.

CRS Deadline: 31 August 2020.


Links:

Russia CRS Guidance

New September Deadlines


Cayman Islands


CRS and FATCA Deadline: 18 September 2020.

Rule Updates: The Authorising Person (“AP”) and Principal Point of Contact (“PPoC”) does not have to be an individual. Please keep in mind that the regulations require the AP and PPOC must be two different persons, excepts where the Authority specifies – that the Financial Institution elects to appoint an entity that is licensed under regulatory laws of the Cayman Islands Monetary Authority as the AP and PPOC.

On the new DITC Portal, the FI can chose to either have an individual or an entity as the PPoC or AP. See Guidance for Institutional Users for FATCA and CRS.

Portal Updates: The Cayman Islands Automatic Exchange of Information (AEOI) Portal offline. The DITC are developing a new Portal (called the DITC Portal) for registration (notification) and reporting purposes, which will eventually encompass all legislative frameworks. This new portal will launch in June 2020. All functionality (notifications and reporting) will be available at that time. In recognition of the change in launch date, the deadline for 2019 FATCA and CRS reporting (only) will be 18 September 2020.

All user accounts from the AEOI Portal will be migrated to the new DITC Portal along with their assigned FIs. APs and PPoCs should expect an email from the DITC in June, which will contain steps on how to log onto the DITC Portal. Further details on this process will be posted here in due course.


Links:

CRS Reportable Jurisdictions

Cayman News and Updates

2020 Cayman Guidance Notes

US IRS


In the last two weeks, the Internal Revenue Service (IRS) posted the following changes:

IRS Operations During COVID-19: Mission-critical functions continue

FATCA Filing Extension. On March 30, the IRS announced that it will provide an extension of time for a Reporting Model 2 FFI or a Participating FFI to file the FATCA Report (Form 8966). The filing deadline for the FATCA Report will be extended from March 31, 2020 to July 15, 2020. Form 8809-I, Application for Extension of Time to File FATCA Form 8966, will not be required for this extension.

For all other updates and additional information please visit the following links:

The IRS:

https://www.irs.gov/coronavirus

The Department of Treasury:

https://home.treasury.gov/coronavirus

The U.S. Government:

https://www.usa.gov/coronavirus (In English)

https://www.usa.gov/espanol/coronavirus (In Spanish)

Update on OECD Tax Work:

https://search.oecd.org/tax/beps/coronavirus-covid-19-update-on-oecd-tax-work.htm

Center for Disease Control (CDC):

https://www.coronavirus.gov/


How to Implement


Visit these websites often to stay informed of changes, both tax and health related!

Share your experiences with us in the comments or e-mail us!

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