Yesterday, a Joint Statement was released by the Early Adopters Group of the OECD's Common Reporting Standard (CRS) confirming their commitment to the new standard for automatic exchange of information and proposing a timetable for implementation. In summary, this means that for early adopters CRS will begin for new accounts from 1 January 2016 and pre-existing accounts will be those maintained as at 31 December 2015.
Following the release of the CRS on 13 February 2014, the Joint Statement by the Early Adopters Group (now 44 countries) recognises that the proposed timetable is ambitious but achievable. The timetable provides that:
- Pre-existing accounts are those open as at 31 December 2015.
- New accounts will be those opened from 1 January 2016 and relevant procedures to record tax residence should therefore be in place by then.
- Due diligence will be required to be completed by 31 December 2016 for high-value pre-existing individual accounts and by 31 December 2017 for low value pre-existing accounts.
- The first exchange of information in respect of new accounts and pre-existing high value accounts will be by the end of September 2017.
- Information on pre-existing low value accounts and entity accounts will first be exchanged either by the end of September 2017 or September 2018 depending on when they are identified as reportable by a Financial Institution.
The Joint Statement can be accessed here. Should you have any questions please contact me or visit our website at www.deloitte.co.uk/FATCA.
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