Reportable Accounts

A Reporting Financial Institution is required to identify reportable accounts. A reportable account is a financial account held by one or more reportable persons or by a Passive Non-Financial Entity (PNFE) with one or more reportable controlling persons.


Reportable Persons - Individuals

For accounts held by individuals, the individual will only be reportable if they are resident for tax purposes in a reportable jurisdiction. For the purposes of FATCA, the reportable jurisdiction is the United States. For the CRS, reportable jurisdictions are those with which the reporting jurisdiction has an exchange relationship in place. Individual jurisdictions publish lists of reportable jurisdictions for the purposes of CRS reporting and a full list of Activated Exchange Relationships is published by the OECD.


Reportable Persons - Entities

For entities (companies, partnerships, trusts etc) the position is slightly more complicated. An entity, if it is not a Financial Institution, will be classified as a Non-Financial Entity (NFE). Such entities may then either be classified as Active NFEs or Passive NFEs.


Active NFEs are required to be reported where the entity is resident for tax purposes in a reportable jurisdiction.


Passive NFEs - the controlling persons of those entities (for example the controlling shareholders of companies, partners in a partnership or the settlor, trustees or beneficiaries of a trust) are required to be reported if they are resident for tax purposes in a reportable jurisdiction. Details of the Passive NFE are also required in this case.


Examples
  1. UK Bank Plc holds a deposit account for Paris Designs SARL, a French trading company. This would be classified as an Active NFE and, because it is resident in a reportable jurisdiction, would be a reportable person.

  2. UK Bank Plc holds a deposit account for London Trading Company Limited, a UK trading company. This would be classified as an Active NFE and, because it is UK resident (the same jurisdiction as the Financial Institution), is not a reportable person.

  3. UK Bank Plc holds a deposit account for Grey Investments Limited, a UK investment company with two controlling shareholders, Mr Grey (UK resident) and Mrs Grey (French resident). If Grey Investments meets the criteria for being classified as a Passive NFE, UK Bank Plc would be required to report details of Grey Investments Limited and Mrs Grey (as a reportable controlling person) but would not report the details of Mr Grey (as he is resident in the UK).

ID card

What is reported?

The following details are reported for each reportable account;

  • Account number or identifier
  • Account balance at 31st December
  • Income paid or credited to the account for the year split between four categories (interest, dividends, proceeds from sale or redemption of property and other income).
  • Account holder name, address and Tax Identification Number (TIN)
  • In the case of individuals, the date of birth and, in certain cases, the place of birth

In addition, for each controlling person of a Passive NFE, that controlling person's name, address, TIN, date of birth and, if required, place of birth