IEIM904220 - Financial Account Identifiers

Financial account identifiers can be particularly useful to tax authorities when it comes to matching datasets, because this information tends to be highly reliable. However, because this information is sensitive, financial account identifiers should only be reported for Sellers where the jurisdiction where the Seller is determined to be resident has stated that it requires the information to be reported.

Financial account identifiers are the unique identifying number(s) or reference(s) used to identify a particular financial account, which are available to the Reporting Platform Operator (RPO). For UK accounts, these would normally be the account number and sort code. It could also be an IBAN number, or other equivalent identifier used in another jurisdiction.

For Sellers who are UK resident, HMRC has determined that it does require this information to be reported, as it will help us to match reported data to existing datasets more effectively. As other jurisdictions implement their equivalent domestic legislation, and indicate whether they require financial account identifiers to be reported, HMRC will update this guidance. If a jurisdiction does not indicate that it requires financial account identifiers, then this information should not be reported to HMRC by RPOs. If it is incorrectly reported, HMRC may contact the RPO and ask them to amend their submission to remove this information.

Financial account identifiers are only required to be reported where they are available to the RPO. Therefore, RPOs do not need to collect this information from Sellers if they do not already collect it as part of their business operations. In this context, financial account identifiers are available to the RPO even if the processing of payments has been subcontracted by the RPO to another entity, and the financial account identifiers are normally held by that other entity.

If the account to which Consideration is paid is not in the Seller’s name, the RPO will have to report the name of the person or entity that is the account holder if that information is available to them. This should be reported in addition to the information collected by the Platform, and there are different fields in the reporting schema for this information. The RPO should also report any other identifying information they have about the account holder e.g. the address of the account holder if it is known to the RPO.

Consideration is defined as the amount ‘paid or credited’ to the Seller and the amount of Consideration should be calculated on a ‘cash basis’, i.e. the amount actually received by or credited to the Seller in a Reportable Period after deducting any refunds or cancellations made in that period. It should not be determined on an ‘accruals basis’ based on the goods or services provided in the Reportable Period but where payment for some of those goods or service has not yet been made.

Similarly, where Consideration is received for services or goods that are yet to be provided, if the Consideration is known, or reasonably knowable, such a transaction is reportable.

For an individual Seller resident in the UK, the TIN will normally be the Seller’s National Insurance Number (NINO). For an Entity Seller resident in the UK, the TIN will normally be the Company Registration Number (CRN).

For non-UK resident Sellers, the TIN will depend on the jurisdiction of residence. The TIN reported should be the TIN collected by the RPO (see IEIM902330).