IEIM402540 - Due Diligence: General Requirements: Reportable Account: Examples

Due Diligence: General Requirements: Reportable Account: Examples

The following examples illustrate the circumstances where an account becomes or ceases to be a Reportable Account.

1) Account becomes reportable – a Financial Institution carries out due diligence procedures on lower value pre-existing accounts as at 31 December 2015 for CRS purposes between 1 January 2016 and 31 December 2017. On 22 March 2017 the Financial Institution identifies an account that belongs to an individual resident in Italy. The account is a Reportable Account from that date. Information on that account is reportable for the full calendar year 2017, the first report being made in 2018 and annually thereafter.

2) Account reportable after change of circumstance – a new account is opened by an individual on 20 June 2016. The self-certification provided by the individual on opening the account shows that the individual is tax resident in the UK. The account is not a Reportable Account. On 13 September 2018 the individual notifies the Financial Institution of a move to Germany to work and provides the Financial Institution with a residential address in Hanover. This provides an indicia of tax residence in Germany which is a change of circumstance [see IEIM403200]. The account becomes a Reportable Account and is reportable for the full calendar year 2018, the first report being made in 2019 and annually thereafter.

3) Account ceases to be reportable – the Account Holder of the account in example 1 above notifies the Financial Institution that they have moved permanently to the UK and are resident there for tax purposes with effect from 17 April 2019. As a result, the individual ceases to be a Reportable Person. As the account ceases to be a Reportable Account in the calendar year 2019 no report from the Financial Institution is required in 2020 or any subsequent calendar year unless the account becomes reportable once again.

4) Account is closed – a Reportable Account is closed by the Account Holder on 14 August 2018. The Financial Institution must report in 2019 that the account has been closed along with information in respect of that account for the period from 1 January 2018 to the date of closure. The amount of information will depend on the regime under which reporting occurs [see IEIM402170].

5) Account ceases to be reportable and is then closed – the Account Holder in example 3 above closes the account with the Financial Institution on 11 October 2019. As the closure occurred after the account ceased to be reportable, information with respect to the closure of the account is not required to be reported in 2020.