Ireland: Updated FATCA and AEOI guidance

The Irish Revenue Commissioners on November 1, 2024, published updated guidance notes on the implementation of FATCA in Ireland, updated Irish filing guidelines for FATCA, and an updated revenue guide to automatic exchange of information (AEOI) for account holders.

• The updates to the guidance notes on the implementation of FATCA include revisions to Section 4.3 regarding taxpayer identification numbers (TINs). Revenue clarified that temporary relief for missing TINs is contingent on reporting a date of birth for the account holder or controlling person. For new accounts, a U.S. TIN placeholder code must be reported if a TIN is unavailable, and non-compliance will be assessed based on specific circumstances.
• In the Irish filing guidelines for FATCA, Section 7.5 was updated to specify that a U.S. tin placeholder code needs to be used when a date of birth is provided instead of a TIN. Section 7.6 mandates reporting the account holder's date of birth and a placeholder code to utilize IRS temporary relief procedures.
• The revenue guide to AEOI for financial account holders now includes guidance in Section 12 encouraging U.S. account holders to provide their TINs to Irish financial institutions, emphasizing the importance of compliance for reportable accounts under FATCA.

Read a November 2024 report prepared by the KPMG member firm in Ireland