The British Virgin Islands International Tax Authority (ITA) has launched its BVI Financial Account Reporting System (BVIFARS). The portal was opened yesterday and is ready to accept enrolment applications from BVI Reporting Financial Institutions (FI) which are required to submit information under the Intergovernmental Agreement (IGA) between the BVI and the US.
BVI Reporting Financial Institutions and Sponsoring Entities are
required to enrol with BVIFARS prior to submitting FATCA
information to the ITA. The deadline to register in order to submit
information in the 2015 reporting cycle is 1 June 2015. Enrolment
is a one off exercise but is subject to review and approval by the
ITA – it is unclear exactly how long the process will take so
Financial Institutions are advised not to leave enrolment until
close to the deadline. As previously announced, the reporting
deadline for the 2014 period is 30 June 2015 with the deadline in
subsequent years (2016 onwards) being 31 May.
Once the application for enrolment is approved, a Financial
Institution profile is created and the BVI Reporting FI will be
provided an automated unique identification number. Each BVI
Reporting FI will have a Primary User who will have the ability to
create up to three additional Secondary Users. Financial
Institutions are required to submit their registered name,
institution type and GIIN as part of the enrolment process.
Although the enrolment process is conducted entirely online, the
Primary User is required to upload a scanned copy of his or her
passport and a letter signed by a director of the Financial
Institution specifying that person as the person responsible for US
FATCA compliance.
It is important to note that as the ITA does not require Financial
Institutions to submit NIL reports. The ITA does not require
Financial Institutions to enrol with BVIFARS if that Financial
Institution has nothing to report. However, BVIFARS will accept a
NIL report if a Financial Institution wishes to submit one.
Equally, a Financial Institution with nothing to report may enrol
and not submit a NIL report.
The Government has produced a User Guide to BVIFARS. It contains detailed
step by step guidance as well as some Quick Reference Guides and
Frequently Asked Questions. FATCA guidance notes are also available. The
Government's press release is available online.
Harneys can assist clients with the enrolment process and
provide a host of other advisory and reporting services related to
FATCA.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.