Updated FAQs dealing with due diligence obligations
The tax administration of Finland on January 22, 2025, updated Section 2 of its FATCA and common reporting standard (CRS) “frequently asked questions” (FAQs), dealing with due diligence obligations.
Specifically, an additional question was added regarding whether reporting financial institutions can rely solely on an account holder's global intermediary identification number (GIIN) to identify it as a financial institution.
The FAQ notes that a valid GIIN, as listed on the U.S. tax authority’s (IRS) list of financial institutions, is a factor in the assessment, but it is not sufficient on its own. Reporting financial institutions must also consider other factors, such as self-certifications, publicly available information, and anti-money laundering or know-your-customer (AML/KYC) documentation, to reasonably determine an account holder’s status as a financial institution.
Read a February 2025 report prepared by the KPMG member firm in Finland