Liechtenstein: Updated CRS guidance for AEOI
Revision of automatic exchange of information sheet under CRS regime
The tax authority of Liechtenstein on 3 May 2024 issued Newsletter 04/2024 announcing the revision of the automatic exchange of information (AEOI) sheet under the common reporting standard regime.
The information sheet is updated to address a recommendation from the ongoing Effectiveness Assessment of the Global Forum on Transparency and Exchange of Information for Tax Purposes. Per the assessment, Liechtenstein’s implementation of common reporting standard (CRS) is assessed positively in broad areas but needs improvement in specific areas.
The revised information sheet implements a recommendation concerning the "Day 2 Procedure" for new accounts, including new bank accounts, new insurance contracts, new donors, discretionary beneficiaries, etc. It clarifies that for a self-disclosure to be valid and complete, a tax identification number (TIN) must be obtained at the time of opening the account. In addition, the self-disclosure must be verified for plausibility, either immediately or within 90 days if conducted by the back office. If there is no valid and plausible self-disclosure, the account must be blocked for all additions and withdrawals or payments of distributions, repayments, etc. If no self-disclosure is provided within 90 days of opening the account, reporting based on available evidence must occur from the reporting period in which the account was opened, and efforts need to be made to procure a valid and plausible self-disclosure.
Lastly, financial institutions are reminded not to solely rely on the FATCA foreign financial institution list for AEOI due diligence obligations concerning the determination of the financial institution status for legal entity accounts.
Read a May 2024 report prepared by the KPMG member firm in Liechtenstein