
The deadline for all Qualified Intermediary (QI) (including Qualified Derivatives Dealer), Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) applications for the 2025 year is September 30, 2025.
Applications must be submitted through the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application & Account Management System (QAAMS) and any applications submitted after September 30, 2025, will not be processed.
All Bermuda Reporting Financial Institution (RFIs) and Trustee-Documented Trusts (TDTs) must submit the CRS Compliance Form no later than September 30, 2025.
All Cayman Island Financial Institutions (FIs) with a CRS reporting obligation must submit the 2024 CRS Compliance Form by September 15, 2025.
The IRS released the following DRAFT forms during the month of August:
On July 30, 2025, OECD issued a new set of frequently asked questions (FAQs) to provide interpretative guidance on the Crypto-Asset Reporting Framework (CARF) and the amended Common Reporting Standard (CRS).
On August 18, 2025, the OECD published updated information on Tax Identification Numbers for Uruguay and Tax Residency information for Panama.
On August 18, 2025, the Inland Revenue Authority of Singapore (IRAS) posted an update regarding the CRS XML Schema Version 3.0. Beginning January 1, 2027, all CRS returns in XML format must be formatted and submitted using the OECD Common Reporting Standard XML Schema version 3.0.
IRAS will release, in due course, the updated edition of the IRAS XML Schema User Guide for CRS Return which will explain the information required to be included in each element to be reported in the CRS XML Schema v3.0.
On August 5, 2025, HMRC updated its International Exchange of Information Manual (IEIM), section IEIM402880, Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Curing Indicia. The update provides additional information regarding FATCA and US place of birth.
Additionally, on August 6, 2025, HMRC also updated IEIM, section IEIM905400, Circumstances in which a Penalty will not Apply. This section was changed to include reasonable care, as well as reasonable excuse.



August is traditionally a quieter month, but for us it’s a valuable time to work behind the scenes. We’re using this period to prepare for the final few months of the year and the inevitable busyness of year-end reporting. It’s also given us the space to focus on an exciting new project that we look forward to announcing very soon.