Ireland: Increased AEOI compliance reviews; other FATCA and CRS developments in 2022

Tax authority has been issuing letters to entities across various sectors

Other FATCA and CRS developments in 2022

The tax authority has been increasing FATCA and common reporting standard (CRS) compliance review over the last few months to assess whether Irish entities are complying with the Irish FATCA and CRS provisions. To help facilitate the review, the tax authority has been issuing letters to entities across various sectors covering:

  • Profile interviews with financial institutions—this involves a financial institution being selected and required to respond to a questionnaire in advance of a meeting with the tax authority
  • Failure to file notices to financial institutions that have registered a FATCA and/or CRS reporting obligation via the Revenue Online Service (ROS), but have not filed the relevant FATCA and/or CRS return by the appropriate 30 June deadline
  • Specific AEOI-related questions, such as inquiring: (1) an entity’s FATCA/CRS classification; (2) a financial institution’s compliance with a specific aspect of the Irish FATCA and/or CRS provisions; (3) whether an entity received certain foreign income and correspondingly paid Irish tax on such foreign income (as appropriate) based on details of foreign income that the tax authority has received via information exchanged under CRS by foreign tax authorities

Typically, the tax authority has been initially issuing letters which reflect a “Level 1 Compliance Intervention.” Irish entities need to give these letters proper attention so the matter is not escalated to a Level 2 or 3 Compliance Intervention and to mitigate the risk of penalties being applied.

Read a November 2022 report prepared by the KPMG member firm in Ireland, which also provides information on the following FATCA/CRS-related developments in 2022:

  • The tax authority in May 2022 published an updated list of participating jurisdictions for CRS and DAC2 purposes, bringing the total number of participating jurisdictions to 115.
  • The tax authority in June 2022 published an updated “Chapter 10 – Approved Profit Share Schemes (APSS)” guidance via to address how an APSS is to be treated for Irish FATCA and CRS purposes.


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