On 2 April 2024, the Irish Revenue Commissioners (“Revenue”) published updates to the Irish CRS FAQs Tax and Duty Manual (“TDM”) – Standard for Automatic Exchange of Financial Account Information in Tax Matters – The Common Reporting Standard (CRS) (Part 38-03-23). Kevin Cohen of our FATCA team explains below.
The CRS TDM includes the following updates:
- FAQ16 was updated to expand the requirements of what is expected of Reporting Financial Institutions (“FIs”) when performing a “Reasonable Check” on CRS Self-Certification Forms when relying on (i) Global Intermediary Identification Numbers (“GIINs”) for entities, or (ii) certain high-risk Residence/Citizen by Investment schemes for individuals.
- FAQ19 was added to provide further guidance on when an Irish regulated fund (umbrella or sub-fund) ceases to be considered a Reporting FI and become closed for CRS reporting purposes.
Further commentary on the above items is included at this link. This alert also includes other FATCA/CRS related developments since our previous alert below.
By way of reminder, the Irish FATCA and CRS return filing deadline for the 2023 reporting year is 28 June 2024 (as 30 June falls on a Sunday this year). Based on recent discussions with Revenue, we understand that they are increasing their focus on ensuring that accurate and complete FATCA and CRS Returns are filed on a timely basis. Additionally, Revenue have indicated that penalties will be levied in relation to 2023 reporting where multiple Non-Filer Letters are issued to Reporting FIs and the Reporting FI continues to either not file or file its FATCA and CRS Returns late.
Should you require any assistance with meeting your reporting obligations under FATCA and CRS ahead of the 28 June 2024 deadline, please contact a member of our AEOI team.
Get in touch
Should you require any assistance with meeting your FATCA and CRS obligations please contact Kevin Cohen of our FATCA team.
We'd be delighted to hear from you.
Kevin Cohen
Partner
KPMG in Ireland