CRS is a globally co-ordinated approach to the disclosure of financial account information in respect of individuals and organisations in order to combat tax avoidance. CRS imposes obligations on financial institutions (FIs) including Bank of Ireland, to review and collect information to identify an account holder’s country of tax residence and then provide certain account information to the Irish Revenue Commissioners (IRC).
Background to CRS
CRS was approved by the Organisation for Economic Cooperation and Development (OECD) in July 2014. A number of jurisdictions have committed to implementing CRS with a subset of the participating jurisdictions, including Ireland, signed up to be ‘early adopters’; i.e. adopting the CRS reporting rules with effect from 1 January 2016. Other participating jurisdictions will follow in 2017 and subsequent years.
Section 891F of the Taxes Consolidation Act 1997 implements CRS under Irish Law.
For Bank of Ireland this means that all accounts opened from 1 January 2016 will have to capture new details from a customer such as the customer’s tax residency, Tax Identification Number (TIN) and date of birth, which may be required to be reported, along with some account details (including the account number, account balance or value and certain gross amounts paid or credited to the account), to the IRC from 2017. Bank of Ireland will also be required to review any accounts in existence as at 31 December 2015 to determine if they are reportable and, if so, provide this information to the IRC. The IRC will then separate out the information received by jurisdiction and will report the customers’ details to other participating CRS jurisdictions.
CRS introduces important new obligations that you need to be aware of.
When opening personal accounts from 1 January 2016 onwards, the financial institution must obtain self-certification from the customer as part of the account opening documentation. This self-certification is required to (a) determine the account holders’ residence(s) for tax purposes, and (b) obtain the applicable foreign TINs if appropriate. The financial institution must also confirm the reasonableness of the self-certification based on information obtained in connection with the account opening.
If a customer has a non-Irish tax residency and does not provide us with a foreign TIN, we cannot open the account.
This agreement is separate to The Foreign Account Tax Compliance Act (FATCA) which relates only to customers who are citizens of the United States or are resident for tax purposes in the United States. CRS will report on a wider range of tax residency jurisdictions. The current process for asking and recording FATCA questions for personal customers will continue to be followed. The process outlined above is an additional mandatory step for capturing CRS information for personal customers
Bank of Ireland is not liable for the accuracy of the information contained on any third party website.
In accordance with the Foreign Account Tax Compliance Act (‘FATCA’) and the OECD Common Reporting Standard (‘CRS’), Bank of Ireland may be required to report certain account holder details to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in the relevant jurisdictions. Please note that Bank of Ireland does not provide tax advice and will not be liable for any errors contained in the self-certification form. If you have any questions about FATCA/CRS you should contact your tax advisor or the Irish Revenue Commissioners.