FACTA/CRS Self Certification – What financial institutions should know?

While opening an account with the bank or during the CRS reporting cycle, banks may send a declaration form something in the name of “Tax Residency Self-Certification Declaration form” or “CRS Entity Self-certification form”. This form is being sent to account holders to certify about themselves to identify their tax resident countries and other related information. This form generally contains the Account Holder’s (i) name, (ii) residence address, (iii) jurisdiction(s) of residence for tax purposes, (iv) tax identifying number for each Reportable Jurisdiction, and (v) date of birth.

Financial institutions are directed to collect and report certain information from their account holders (individual or entities) to the tax authorities. This information will help the financial institutions to classify the reportable accounts whether the account holder needs to be reported under CRS or FATCA.

As per HMRC guidelines, any individual who opens an account must provide a self-certification establishing where the individual is tax resident. If the self-certification demonstrates that the Account Holder is a tax resident of a Reportable Jurisdiction, the Reporting Financial Institution must treat the account as a Reportable Account.

For tax residents outside the UK, HMRC will ask the financial institutions to share this self-certification information along with the account details. This information will be shared with respective tax authorities outside the UK by HMRC.

It is the responsibility of the account holder to ensure that the personal information shared by them is correct and up to date. By completing this form, the account holders ensure that they shared accurate and up-to-date information about their tax residency. Unless there is a change in circumstances that impacts the tax resident status or any information submitted in the form becomes erroneous, the CRS form will remain valid. If any of the personal details change, the account holder must notify the financial institutions within 30 days of any change in circumstances that affects their tax residency status or causes the information held to become inaccurate, and the account holder must provide an updated self-certification and declaration within 90 days of such a change.

Participating jurisdictions are expected to provide information to help taxpayers determine their tax residence(s). After obtaining a self-certification, the Reporting Financial Institution must confirm its reasonableness based on the information obtained in connection with the account opening, including any documentation collected according to AML/KYC procedures (the reasonableness test).

If a Reporting Financial Institution does not know or has reason to believe that a self-certification is incorrect or unreliable, it is considered to have confirmed its reasonableness. When a self-certification fails the reasonableness test, the Reporting Financial Institution is required to obtain either a valid self-certification or a reasonable explanation and documentation, as appropriate, supporting the reasonableness of the self-certification.

The Reporting Financial Institutions will always be held accountable for their reporting and due diligence obligations, including confidentiality and data protection obligations.

Each jurisdiction may permit Reporting Financial Institutions to use service providers to meet their reporting and due diligence requirements. Macro Global is one of such technical service providers in the RegTech & FinTech space delivering the best-in-class products to the financial industries. Macro Global has been consistently recognised for its exceptional outcomes and services around Regulatory Reporting for the past 20 years. Macro Global’s CRS Stride, FATCA & Common Reporting Standard solution features a centralised, fully automated Self-Certification module which includes the entire process cycle of classification, customer communication, correction, and consolidation for CRS and FATCA reporting.

CRS Stride generates a filled-in self-certification declaration form in PDF format from the CRS input data as per the HMRC CRS reporting guidelines. Banks can send the filled-in self-certification form to the account holder’s email inbox from the CRS Stride portal itself in just a single click. The account holders have to send the duly signed-in self-certification form back to the bank. This process is made simple as account holders are no longer needed to reach out bank’s customer service for additional information.

MG’s approach in implementing the CRS FATCA reporting solution is crafted to achieve maximum operational efficacy by easing the data management process to ensure data integrity and CRS report accuracy.

In-built Data Correction feature in the CRS Stride reporting solution enables to rectify inaccuracies and redundancies in source data to append/enrich for more complete and accurate reporting on our platform.

Our Tax Experts will do Assurance validation, providing peace of mind that the data is in a good shape with high accuracy and compliance before submitting to HMRC.

CRS Stride – FATCA & CRS Reporting software is available to you from the moment an amendment is published by HMRC to implement control mechanisms and audit-proofing.

Looking for a fully automated CRS FATCA reporting solution? Try CRS Stride today and see how it can power up your CRS FATCA Reporting program!

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