Common Reporting Standard (CRS) Important Information

Tax Identification Numbers

Jurisdictions have provided information on the OECD’s website as it relates to the issuance, use, construct, and validity of Tax Identification Numbers commonly known as “TINs”.  Where a jurisdiction does not issue a TIN, that jurisdiction may use a functional equivalent that is acceptable for CRS purposes.  Please note that if there is any doubt as to the jurisdiction-specific information provided, please seek professional consultation.  Please click here for more Jurisdiction specific information on TINs.


Tax Residency Rules

Tax residency is determined by domestic legislation of a jurisdiction.  As such, jurisdictions have provided information on the OECD’s website as it relates to tax residency rules.  It is essential that Virgin Islands Financial Institutions properly apply the due diligence procedures to determine where an account holder may be a resident for tax purposes under CRS.  Please note that if there is any doubt as to the jurisdiction specific information provided, please seek professional consultation.  Please click here for more jurisdiction-specific information on tax residency rules.


Residence/Citizenship by Investment

Residency by Investment or Citizenship by Investment (“RBI” or “CBI”) are measures implemented by some jurisdictions that offer residency rights or citizen rights to persons via investments or for a fee.  Financial Institutions should be cognizant that in some circumstances, these measures could be misused for CRS purposes.  The OECD has analysed how such measures can be termed as high-risk.  Please click here for more information on RBI & CBI measures.


Undocumented Accounts

An undocumented account generally arises when a Financial Institution locates a “hold mail” or an “in-care-of” indicium associated with the account, and no other address is on file associated with the account.  As such, Financial Institutions are unable to determine the true and correct residency status(s) of the account holder.  In such cases, the account will be reported domestically (in the BVI FARs Portal) as “undocumented”, until there has been a change in circumstances.  It is only in such circumstance an account is considered undocumented.  For more information on the Due Diligence Procedures required under CRS specifically for pre-existing individual accounts, please click here to access the Commentaries on the Common Reporting Standard Section III, Paragraph’s B to E, pages 111-124. Alternatively, click here where the Standard for the Automatic Exchange of Financial Account Information in Tax Matters, 2nd Edition, can be accessed on the OECD’s website.