One of the most challenging aspects of AEoI reporting is tracking and implementing the different requirements for different jurisdictions. Whilst the overall reporting requirements and principals are universal, the key areas of regional difference are;
In most cases jurisdictions specify that the standard OECD schema is to be used for CRS reporting and the US FATCA schema for FATCA reporting, however some jurisdictions have developed their own schemas which Financial Institutions are required to use. Examples of jurisdictions which have taken this approach to date are;
Where jurisdictions specify their own schemas to be used, this provides the tax authority with the ability to introduce their own data fields and validation checks and ensures greater integration with their own systems. It also presents the following additional challenges for Financial Institutions;
In most cases tax jurisdictions offer a portal where the Financial Institution's representative or agent logs in and uploads the .XML file, however there are some exceptions to this;
Most jurisdictions require two returns to be submitted for each Financial Institution, one for CRS (containing details of all reportable investors) and a separate US FATCA return (containing details of US reportable accounts).
There are some notable exceptions to this;
Each FATCA or CRS return and each reportable account contained within the return should have a unique reference (often referred to as the Message refs and Doc refs). Some jurisdictions specify with precision the exact format which they require, whereas others simply require the Financial Institution to ensure that it is universally unique.
Some jurisdictions require Financial Institutions to notify where they have no reportable accounts (a nil return) whereas most do not. The format of this nil return also varies between jurisdictions, in some cases it is in .XML format (similar to a return containing reportable accounts) and in other cases no XML file is required but instead the user records the fact that there is nothing to report on the relevant portal.
Submission deadlines vary between jurisdictions, some are as early as February or March following the reporting period, most are in June and exceptionally some are as late as July or August. In the early years of FATCA and CRS extensions were granted by some jurisdictions while systems were being established. In 2020 many jurisdictions also deferred submission deadlines due to the global Coronavirus pandemic.
The level of validation checks on specific data field formats varies between jurisdictions. For example, some jurisdictions require that the City field of the account holder's address is completed in all cases, whereas some do not. Certain jurisdictions may implement additional validation checks based on the expected format of national identification numbers.