FATCA & Exchange of Information

www.istructuring.com
FATCA & Exchange of Information
January 27 12:00 – 12:45 GMT
Ross Belhomme, Saffery Champness
Peter Grant, KPMG

CLIENT PFFI
FORM
8966
FORM
8938
FBAR
CROSS CHECK AND
EXCEPTION REPORT
• Request for information?• Request for information?

TAX COLLECTION
INSTITUTION
ENTERS GLOBAL TAX
IDENTIFICATION NUMBER
“GY234320FZDF”

• ACCOUNT DETAILS
• DETAILS OF INCOME
• DETAILS OF GAINS
• ACCESSIBLE BY
COUNTRY
GERMANY
BASED AGENT
GERMAN
STEUERAMT
FRANCE
FISCALE
FRANCE
BASED
AGENT
SPANISH
BASED AGENT
SPANISH
FISCALE
HMRC
UK BASED AGENT
US BASED AGENT IRS
GERMANY
BASED AGENT
FRANCE
BASED
AGENT
UK BASED AGENT

ROSS BELHOMME
EXECUTIVE DIRECTOR
SAFFERY CHAMPNESS (SUISSE) SA
7 AVENUE PICTET-DE-ROCHEMONT, GENEVA
SWITZERLAND
ross.belhomme@saffery.ch
www.saffery.ch
https://ch.linkedin.com/pub/ross-belhomme

Common Reporting Standard
(CRS)
27 January 2015
Peter Grant: Operational Taxes Director
peter.grant@kpmg.co.uk

8
© 2015 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
Agenda
1.Background of CRS
2.Interaction between FATCA and CRS – Key Differences
3.Key Dates for CRS Implementation

10
Background of CRS
QI EUSD
US
FATCA
IGA
FATCA
DAC, EUSD,
EU Project
OECD
CRS
Begin of an automatic
exchange of
information in favour
of the US limited to
non-US taxpayers
earning US sourced
income
Mutual exchange of
information for the
domestic taxation of
foreign interest
income and revenues
applied by EU
member states (with
the exception of
Austria and
Luxembourg) and
certain non-EU
member states
A comprehensive
automatic exchange
of tax information
relating to US
taxpayers earning
non-US sourced
income
Bilateral
intergovernmental
agreements
concerning the
implementation of
FATCA
Proposed
amendments to the
EU Savings Directive,
the Directive on
Administrative
Cooperation, and EU
project in order to
achieve a
comprehensive
reporting standard
within the EU
analogue to FATCA
G8 / G20 mandates
the OECD to develop
a global reporting
standard to achieve a
comprehensive and
multilateral automatic
exchange of
information
2001 2005 2010 2012 2013 2013-2014

11
Development of CRS
G-20 Calls on OECD to Develop Multilateral Standard for Automatic Exchange of Financial Account Information
in September 2013
OECD Develops CRS Together with G-20 Countries
■ OECD works with the Business and Industry Advisory Committee via a special Business Advisory Group
■ February 2014: OECD releases and G-20 approves CRS
■ July 2014: OECD issues Standard for Automatic Exchange of Financial Information in Tax Matters:
– Model Competent Authority Agreement (CAA)
– Common Reporting Standard (CRS)
– CRS Commentary
■ September 2014: G-20 calls on all financial centers to commit by October 2014 to adopt the CRS and automatic
exchange of information
■ October 2014: 51 jurisdictions, 39 of which were represented at ministerial level, signed a multilateral competent
authority agreement to automatically exchange information based on Article 6 of the Multilateral Convention.
Background of CRS

12
OECD Report to the G8, June 2013
■ Scope of financial institutions
required to report: banks, brokers,
collective investment vehicles,
insurance companies.
■ Scope of financial information
reported investment income covered:
interest, dividends, similar types of
income. Requiring information about
account balances.
■ Scope of accountholders subject
to reporting subject to reporting:
individuals and entities.
■ Robust due diligence procedures:
identify reportable accounts, obtain the
accountholder identifying information
that is required to be reported for such
accounts.
■ Legal ability to collect the
information required for due
diligence.
■ Legal basis for reporting
obligation will typically be included
in domestic tax legislation.
■ Legal basis upon which exchange
of information could take place:
– Bilateral treaties
– Nordic Convention
– EU directives
■ Adequate level of data protection
– OECD Guide “Keeping it Safe”
■ Technical reporting formats must
be standardised for quick and
efficient processing in a cost
efficient manner.
■ Methods of transmission and
encryption of data must be in
place. This can be based on
existing methods, e.g. “point-to-
point” portal, CCN Network.
A common schema is being
developed for the standardised model
as well as recommendations on
transmission and encryption.
Common agreement on the
scope
Legal and operational
basis
Common or comparable
technical solutions
Basis for a standardised multilateral automatic exchange model on financial information
Main success factors for effective automatic exchange of financial information
Background of CRS

13
Background of CRS
• A unified ‘big-bang’ of 50+ countries is expected to be followed by the addition of 40+
countries
• CRS impacts the information gathered from every investor and account holder
• Customer information for non-resident investors will be reported locally and then shared
with relevant tax authorities around the world
• Account holder information will be exposed to increased data security risks
• Financial institutions are likely to face increased pressure to demonstrate compliance
• Implementation requires a strategic and flexible approach
• CRS will be implemented across the European Union by way of Directive under the
Directive on Administrative Cooperation (commonly known as “DACII”)

14
Background of CRS
Albania
Andorra
Anguilla
Antigua and Barbuda
Argentina
Aruba
Austria
The Bahamas
Barbados
Belgium
Belize
Bermuda
Brazil
British Virgin Islands
Brunei Darussalam
Canada
Cayman Islands
Chile
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Estonia
Faroe Islands
Finland
France
Germany
Gibraltar
Greece
Granada
Guernsey
Hong Kong
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Japan
Jersey
Korea
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Macao
Marshall Islands
Mauritius
Mexico
Montserrat
Netherlands
New Zealand
Niue
Norway
Poland
Portugal
Qatar
Romania
Russia
Saint Kitts and Nevis
Saint Lucia
Saint Vincent and the
Grenadines
Samoa
San Marino
Saudi Arabia
Seychelles
Singapore
Sint Maarten
Slovak Republic
Slovakia
Slovenia
South Africa
Spain
Sweden
Switzerland
Trinidad & Tobago
Turkey
Turks & Caicos
United Kingdom
United Arab Emirates
Uruguay
Jurisdictions Committed to CRS

15
CRS Popular Myths
CRS
Myths
This is a tax project
Not true. Despite the fact that tax
legislation is driving the need for change,
the real impact will be seen in each
business lines from Fund Administration to
Custody and in areas such as account
opening, customer documentation,
operations and technology. Tax specialists
should be advisors to the project, but not the
driving force.
This doesn’t apply to us
CRS will apply to any entity in a
Participating Jurisdiction that is classified as
a Reporting Financial Institution. There are
no deemed-compliant statuses under the
CRS.
Readiness and
implementation will be easy
We have heard the comment that CRS is
FATCA on steroids and that it will be
reasonably easy to get compliant. The truth
is that CRS is far more wide-reaching than
FATCA and will require a cohesive, multi-
disciplinary effort to ensure readiness.
Since the rules aren’t final,
we can wait to address CRS
While it is true that the rules aren’t final,
KPMG understands the time devoted to
developing business requirements, IT
builds, and testing can take 18 months to 2
years. It is critical to work now with the
limited tax guidance available to make a
preliminary assessment of its ability to
comply with the CRS framework that
currently exists.
Background of CRS

Interaction
between FATCA
and CRS and the
Most Important
Key Differences

17
Country A
Bank
Country A
US
US Account
Holder
Country B
Bank
US Account
Holder
Country B





 Model 1 IGA reporting
 Model 1 IGA exchanges
 Leveraging on Model 1 IGA implementation to
develop standardised automatic exchange in
a multilateral context
Account
Holder
US Bank



1
7
Country B
Account
Holder
Country A
Account
Holder
Interaction between FATCA and CRS and the Key Differences

18
Country A
Bank
Country A
Country B
Account
Holder
Bank
Country A
Account
Holder
Country B
Reporting of information based on
Common Reporting and Due Diligence
Standard (CRS) implemented via
domestic law
18
Automatic exchange of information
based on bilateral treaty, TIEA, or MAC,
& CAA
Reporting of information based on
Common Reporting and Due Diligence
Standard (CRS) implemented via
domestic law
Automatic exchange standard
Basic approach - CRS + CAA = exchange standard

© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG
International”), a Swiss entity. All rights reserved.
Overview of Key Differences Between CRS and FATCA
19
Individuals
• Residence (not including citizenship)
• No thresholds
• Residence address test for pre-existing
accounts building on EU Savings
Directive
• Simplified indicia search
Entities
• Look-through for Reportable Entities that
are Passive NFEs
• Look-through for investment entities in
non-participating jurisdictions
Low risk FIs and products
• General exclusion for country specific low-risk reporting financial institutions and accounts
19
No Withholding

20
Model Competent Authority Agreement (“CAA”) and Model 1 IGA (“IGA”) – Structure
1. Model CAA and Common Reporting Standard – 7 Sections.
2. Annex – Common Standard on Reporting and Due Diligence for Financial Account Information
(“Common Reporting Standard”, “CRS”) – 9 Sections.
1. Agreement between the government of the US and the government of FATCA Partner – 10 Articles.
2. Annex I – Due diligence obligations for identifying and reporting on US Reportable Accounts and on
payments to certain Nonparticipating Financial Institutions.
3. Annex II – Entities treated as Exempt Beneficial Owners or Deemed-Compliant Foreign Financial
Institutions and accounts excluded from Financial Accounts.
Model CAA consists of
Model 1 IGA(a) consists of
Note: (a) Model 1 IGA updated on 4 November 2013.

21
CAA versus Model 1 IGA
Definitions
Definitions
The Section includes limited definitions that are relevant for the exchange of information
between the jurisdictions. The remaining definitions are included in the CRS.
The definition of a Jurisdiction FI
under the CAA, similar to IGA, is
based on place of residence or
branch location. In IGA FATCA
Partner FI may also be identified
based on the place of organization.
The definition of a Jurisdiction Person
refers to the resident of the Jurisdiction,
pursuant to of the due diligence
procedures or an estate of a decedent
that was a resident in the Jurisdiction. A
Reportable Jurisdiction Person
definition focuses on the tax residency
under the law of a jurisdiction rather than
citizenship of the account holder.
Where the term is not otherwise
defined in the CAA, the meaning
under the law of the jurisdiction
applying the CAA should be used.
The CAA envisages consistency of
the meaning of the jurisdiction's law
with the meaning set forth in the CRS.
Section

22
Obligations to Exchange of Information and Time and Manner
■ The exchange of information is based on similar legal basis, the Income Tax Convention or the Convention on Mutual
Administrative Assistance in Tax Matters. IGA additionally refers to the Tax Information Exchange Agreement, whilst CAA
allows for the possibility of using other applicable legal Instrument.
■ The information required to be exchanged are similar to those provided in the Model 1 IGA. Furthermore, the CAA requires
additional information to be exchanged:
– Date of birth;
– Place of birth.
■ The Reporting FI does not have to report the balance or value of the account that has been closed during the year or the
reporting period. However, the FI has to report the closure of the account.
Section 3 differ from that in Article 3 of the IGA as laid out below:
■ CAA limits the exchange of information to the tax years where both jurisdictions have reporting, consistent with the CRS
legislation in effect;
■ Information is exchanged in a common reporting standard schema in Extensible Mark-up Language, while IGA requires
entering into additional agreement or arrangement to establish rules and procedures for the automatic exchange;
Exchange of Information with Respect to Reportable Accounts
Time and Manner of Exchange of Information
Section
Section

23
Compliance, Enforcement, Confidentiality, and Data Safeguards
The CAA is different from the Model 1 IGA, in that;
■ No distinction is made between minor and administrative errors and significant non-compliance;
■ A Financial Institution could not be treated as Nonparticipating Financial Institution under CAA;
■ Reliance of third-party service providers is included in Section II.D of the CRS.
■ The confidentiality and data safeguards rules are similar to the Model 1 IGA, whereby all information
exchanged will be subject to confidentiality rules and other safeguards, including the provisions limiting the
use of the information exchanged. Additionally, safeguards required under the domestic law may be specified
by the supplying Competent Authority;
■ IGA requires providing written notifications by Competent Authorities that appropriate safeguards and the
infrastructure for an effective exchange relationship are in place. There is a possibility of IGA termination on
30 September 2015 if written notifications are not provided. Such written notifications are not required under
CAA.
Collaboration on Compliance and Enforcement
Confidentiality and Data Safeguards
Section
Section

24
Consultations, Amendments, and Terms of Agreement
Terms of Agreement
■ This Section is similar to the Model 1 IGA (Article 10). Notifications are required that necessary laws are in
place (CAA) or necessary internal procedures are completed (IGA);
■ CAA allows for the suspension of the exchange of information in the event of significant non-compliance by
the other Competent Authority.
Article 4 – Application of FATCA to [FATCA Partner] FI,
Article 6 – Mutual Commitment to Continue to Enhance the
Effectiveness of Information Exchange and Transparency;
Article 7 – Consistency in the Application of FATCA to Partner
Jurisdiction; and
Article 9 – Annexes.
Consultations and Amendments
Similar to the Article 8 of the Model 1 IGA.
Section
Section
IGA Articles not included in CAA:

25
CRS versus Model 1 IGA
Due Diligence for Pre-Existing Individual Accounts
■ An exemption for Cash Value Insurance
Contracts or Annuity Contracts, provided
the FI is effectively prevented by law from
selling such Contracts to residents of a
Reportable Jurisdiction (IGA: to US
Residents).
■ Lower Value Accounts
(Balance or value ≤ $1,000,000):
– Electronic Record Search.
■ High Value Accounts
(Balance or value > $1,000,000):
– Electronic Record Search;
– Paper Record Search;
– Relationship Manager Inquiry for
Actual Knowledge.
■ The CRS does not provide for a de minimis carve outs included in IGA;
■ For Lower Value Accounts the CRS provides for a documented residence
address test as an alternative to the Electronic Record Search;
■ Variances in Indicia:
– Place of birth and Nationality are not included in the CRS, since reporting
is based on residence and not citizenship;
– Telephone Number, Standing Instructions, and an “in-care-of” or “hold-
mail” indicia slightly modified;
– Specific procedures for “hold mail” instructions or “in-care-of” address
indicia discovered in the electronic search;
■ The Documentary Evidence to cure the discovered indicia is not specified;
■ The CRS allows one calendar year for completion of the enhanced review of
accounts that are not initially High Value but become High Value accounts in
a subsequent year (Six months under IGA);
■ Enhanced Review procedures may be applied annually to undocumented
High Value accounts;
■ The CRS does not allow to rely on the previously obtained documentation as
a result of fulfilling obligations under other agreements, e.g., a qualified
intermediary agreement with the IRS. It is possible to rely on such
documentation under IGA.
Similarities Differences

26
New Individual Accounts
■ The CRS identification requirements are generally similar
to the IGA, including the requirements to:
– Obtain the Self-Certification; and
– Confirm the reasonableness of the Self-Certification
based on information obtained;
■ CRS include “reason to know” rules to test whether the
original Self-Certification is incorrect or unreliable.
■ The Self-Certification under the CRS requires providing
tax residence(s) of the account holder, while under IGA it
may be interpreted as confirmation whether the account
holder is a resident in the US for tax purposes;
■ The CRS does not provide for a de minimis carve outs
included in IGA;
■ The CRS requires that Self-Certification must include the
Account Holder’s Date of birth, in addition to including the
Account Holder’s TIN. IGA requires only the TIN.

27
Pre-Existing Entity Accounts
■ Carve out for an account with a balance or value ≤
250,000;
■ Similar information/documentation requirements for
determining the FATCA status of the account holder e.g.,
– A place of incorporation or organization, an address in
Reportable Jurisdiction;
– Self-Certification or information in FI’s possession or
that is publicly available;
– Reliance on information collected and maintained
pursuant to AML/KYC procedures.
■ Under CRS accounts that initially do not exceed $250,000
are subject to review when they exceed $250,00 at the
end of the calendar year. IGA requires exceeding the
balance of $1,000,000;
■ The CRS does not require determination whether an entity
account holder is a Nonparticipating Financial Institution.
As a result, payments to Nonparticipating Financial
Institutions are not required to be reported under the CRS.

28
New Entity Accounts
■ Similar identification requirements for determining the
FATCA status of the account holder, including the
requirement to:
– Obtain the Self-Certification; and
– Confirm the reasonableness of the Self-Certification
based on information obtained.
■ The CRS does not provide for the carve out for the credit
card accounts or revolving credit facilitates;
■ Under the CRS, the Reporting FI needs to determine
whether the account is held by one or more Reportable
Persons or Passive NFE with one or more Controlling
Persons that are Reportable Persons. There is no need to
determine any other status, e.g.: FATCA Partner FI,
Jurisdiction FI, a Participating FFI, a Deemed-Compliant
FFI, or an Exempt Beneficial Owner;
■ The CRS does not require determination whether the
entity is a Nonparticipating Financial Institution. As a
result, payments to Nonparticipating Financial Institutions
are not required to be reported under the CRS.
■ For entities that do not have a residence for tax purposes),
the address of the principal office of the Entity is used as a
proxy for purposes of determining its residence;
■ Limited use of the information in possession of the
Reporting FI or information that is publicly available – only
to determine whether the entity is an Active NFFE or
certain type of an Investment Entity. IGA allows to use
Global Intermediary Identification Number to determine
the status of a Financial Institution.

29
Defined Terms
■ The Participating FI test is based on the place of
residence or location of the branch in the Participating
Jurisdiction.
■ The Reporting FI is any Participating FI that is not Non-
Reporting FI.
■ The definition of an Investment Entity is similar to the
definition provided for in Article 1(j) of the IGA. The
“managed by“ definition in the CRS also includes an entity
the gross income of which is primarily attributable to
investing, reinvesting or trading in Financial Assets test.
■ The CRS includes definition of a Financial Asset, which is
not included in the IGA.
■ The terms are similar to the Annex II of the IGA, however
no distinction is made between Exempt Beneficial Owners
and other Non-Reporting FIs.
■ An open definition of the Non-Reporting FI allows
domestic law to treat similar, low-risk entities as Non-
Reporting FIs provided that it does not frustrate the
purposes of the CRS.
■ Certain Non-Reporting FIs from IGA Annex II are not
included (either because they are not appropriate or
irrelevant in a multilateral context) e.g.:
– Treaty-Qualified Retirement Fund;
– Investment Entities Wholly Owned by Exempt
Beneficial Owners;
– FIs with a Local Client Base;
– Local Banks;
– FIs with Only Low-Value Accounts;
– Sponsored Investment Entities and Controlled Foreign
Corporation;
– Sponsored, Closely Held Investment Vehicles;
– Investment Advisors and Investment Mangers.
A. Reporting FI B. Non-Reporting FI

30
Defined Terms (cont.)
■ Under the CRS the definition of a Financial Account includes
equity and debt interests in certain types of Financial
Institutions that are regularly traded on a stock exchange.
IGA excludes these type of interests from the definition of a
Financial Account.
■ The CRS provides a broader set of exclusions from the term
Cash Value and the term Cash Value Insurance Contract
does not include the $50,000 de minimis;
■ The definition of the Excluded Account is similar to the
content of Annex II of the Model 1 IGA. Additionally, the CRS
excludes:
– A Depository Account that resulted from the credit card or
other revolving credit facility overpayment; and
– An open definition that allows domestic law to treat similar,
low-risk accounts as Excluded Accounts provided that it
does not frustrate the purposes of the CRS.
■ The definition of a Reportable Person does not include
the US specific exclusions provided in the definition of
Specified US Person. Instead, it excludes the following:
■ Corporations regularly traded on established securities
markets and Related Entities of the corporations;
– Governmental Entities;
– International Organizations;
– Central banks; and
– Financial Institutions
■ The definition of Passive NFE is expanded to cover
Investment Entities managed by other FIs (e.g., funds)
that are located in non-participating jurisdictions. As a
result these Investment Entities will have to provide
information on the residency of their Controlling
Persons.
C. Financial Account D. Reportable Account
■ The CRS provides that the term ‘control’ in the definition of a Related Entity includes direct or indirect ownership of more
than 50% of vote and value whilst the IGA defines the term as more than 50% of vote or value.
■ Documentary Evidence do not include documents referenced in the attachment to a Qualified Intermediary agreement.
E. Miscellaneous
Interaction between FATCA and CRS

31
Defined Terms (cont.)
This Section contains a similar rule to IGA Article 5(4) Prevention of Avoidance. The CRS, however, includes additional rules
and administrative procedures that an implementing jurisdiction must have in place to ensure effective implementation of, and
compliance with, the reporting and due diligence procedures.
Effective Implementation

Key Dates for
Implementation of
CRS

33
2013 2014 2015 2016 2017 2018
March 31, 2016
Withholding on recalcitrant
account holders not being
reported
May 31, 2016
Annual Form 8966 reporting
and includes aggregated
foreign reportable amounts
paid to NPFFIs
July 1, 2014
• New account due diligence/
identification begins
• Grandfathered Obligations:
Payments on certain
obligations outstanding on
7/1/14 are exempt from
FATCA withholding**
• FFI Agreement becomes
effective
• Reporting FIs with withholding
responsibility must withhold
on US source withholdable
payments made to NPFFIs
FATCA Time Line for Foreign Financial
Institutions (“FFIs”): Model 1 IGA
A
Spring 2014
April 25, 2014
Last date to register with IRS
to ensure inclusion on FFI
List (safe harbor)
June 1, 2014
Reporting FIs with
withholding responsibility
must withhold on US source
withholdable payments to
Related Entities not FATCA
compliant.
June 2, 2014
FFI List published by IRS
June 30, 2015
Deadline for FFIs to
complete remediation
on preexisting
high-value accounts*
January 1, 2017
• FATCA withholding begins
on certain gross proceeds
payments to noncompliant
accounts
• FATCA withholding begins
on foreign passthru
payment (or 6 months after
publication of regulations
defining term, whichever is
later)
• For qualified collective
investment vehicles, date
by which policies aim to
redeem or immobilize
Bearer Interests
December 31, 2014
Deadline for FFIs to
complete
remediation on
preexisting entity
accounts held by
Prima Facie FFIs
(begin withholding)*
J
G March 31, 2015
Withholding on
recalcitrant account
holders not being
reported
May 31, 2015
Form 8966 reporting
for 2014 on US
Reportable Accounts
N
July 12, 2013
Revised Model
IGAs and
accompanying
annexes
released
December 31, 2015
Final date for FFIs to
qualify for Limited
Branch & Limited FFI
Status
March 31, 2017
Withholding on
recalcitrant account
holders not being
reported
May 31, 2017
Annual Form 8966
reporting and includes
aggregated foreign
reportable amounts
paid to NPFFIs.
E
* These dates assume that the PFFI’s FFI agreement is approved by the IRS and effective on July 1, 2014
January 17, 2013
Final FATCA
regulations released
Summer/Fall
2013
IRS portal
anticipated to
open
C
December 31, 2016
Final Day of Transitional Rule
treating U.S. source FDAP payment
paid by non-intermediaries on
offshore obligations as excluded
from definition of “withholdable
payment”
M
L
** Payments treated as dividend equivalents, under section 871(m), may be treated as Grandfathered up to 6 months after the publication of regulation implementing 871(m)
Payments treated as foreign passthru payments may be treated as Grandfathered up to 6 months after the publication of implementing regulations
June 30, 2018
Deadline for
Responsible
Officer to file
certification for
First
Certification
Period
June 30, 2016
Deadline for FFIs to complete
remediation on preexisting
accounts, other than Prima Facie
FFIs and high-value accounts
(begin withholding)*
B
D
F
H
I
August 31, 2016
Due date for
Responsible Officer
due diligence
certifications (unless
previously submitted)*
K
P
O

34
Common Reporting Standard (CRS) Time Line for Early Adopters
Key Dates for Implementation of CRS
2014 2015 2016 2017 2018 2019
A
F
January 1, 2016
CRS go-live date
Accounts opened on
or after this date will
be referred to as ‘new
accounts’
New account opening
procedures must be
in place to record tax
residence
JFebruary 13, 2014
OECD release the CRS
February 22, 2014
G20 endorsed global
standard for AEoI
(including the CRS)
December 31, 2016
Due diligence
procedures completed
for high-value pre-
existing individual
accounts
* Declaration can be accessed at http://www.oecd.org/mcm/MCM-2014-Declaration-Tax.pdf
April 2014
Early adoption
initiative first
launched
May 6, 2014
The new standard
declaration was
signed by more
than 40 countries*
C
December 31, 2017
Due diligence procedures
completed for low-value pre-existing
individual accounts
I
H
September 30, 2018
All information on
reportable accounts will
be available for exchange,
including the low-value
individual pre-existing
accounts and entity
accounts
B
D
E G
September 30, 2017
First exchange of
information for new
accounts and pre-
existing individual high-
value accounts
December 31, 2015
Accounts opened on
or before this date
will be referred to as
‘pre-existing
accounts’
Spring/Summer 2014
Various jurisdictions signed
the Joint Statement by Early
Adopter Group committing to
the implementation strategy
allowing for the first
automatic exchange of
information in 2017; these
jurisdictions will be referred
to as ‘early adopters’

35
FATCA Timeline - Model 1 IGA FIs and CRS (early adopters)
2013 2014 2015 2016 2017 2018
October, 2014
Last date to register with
the IRS to ensure
inclusion on initial FFI
List
September 30, 2017
Competent Authority must
provide required information to
the IRS for 2016
January 1, 2015
Deadline for Reporting Model I
IGA FI to provide upstream
withholding agent with GIIN
G
June 30, 2015
Complete due
diligence for
pre-existing
high value
individual
accounts
M
November 4, 2013
The latest revised
Model IGAs and
accompanying
Annexes released
September 30, 2015
Competent Authority
must provide required
information to the IRS
for 2014
August 19, 2013
IRS registration
portal opened
A
K
September 30, 2018
Competent Authority
information to the IRS
for 2017
June 30, 2016
Complete due diligence for
pre-existing lower-value
accounts and pre-existing
entity accounts
B
D
F
H
September 30, 2016
Competent Authority
information for the IRS
for 2015
Reporting of foreign
reportable amounts to
NPFFIs begins
J
P
July 1, 2014
Treat accounts opened
on or after this date as
new accounts
C
July – October
CRS HMRC Consultation
Request for comments from
Industry
E
January 1, 2016
CRS go-live date for
early adopter countries
I
December 31, 2016
Complete due diligence
for pre-existing high value
accounts N
September, 2017
CRS exchange of
information begins
L
O
December 31, 2017
Remediation of pre-
existing accounts must be
completed
CRS
Model 1 IGA
Key Dates for Implementation of CRS

The information contained herein is of a general nature and is not intended to
address the circumstances of any particular individual or entity. Although we
endeavour to provide accurate and timely information, there can be no
guarantee that such information is accurate as of the date it is received or that
it will continue to be accurate in the future. No one should act on such
information without appropriate professional advice after a thorough
examination of the particular situation.
© 2015 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG
Europe LLP and a member firm of the KPMG network of independent member
firms affiliated with KPMG International Cooperative, a Swiss entity. All rights
reserved.
The KPMG name, logo and “cutting through complexity” are registered
trademarks or trademarks of KPMG International.
In preparing this advice, we considered tax authorities that are subject to change,
retroactively, prospectively, or both, and any such changes could affect the conclusions
stated herein. This advice is based on the completeness and accuracy of any one or
more of the facts, assumptions, and client representations on which we relied, relating
to the matters to which this advice is addressed. Unless separately agreed in writing, we
will not update our advice for subsequent changes or modifications to the law,
regulations, or to the judicial and administrative interpretations thereof, nor to take into
account your correcting, updating, or providing new or additional facts or information
you supplied or any assumptions on which we relied in preparing our advice.
The advice or other information in this document was prepared for the sole benefit of
KPMG’s client and may not be relied upon by any other person or organization. KPMG
accepts no responsibility or liability in respect of this document to any person or
organization other than KPMG’s client.

FATCA & Exchange of Information

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Viewers also liked

Viewers also liked (20)

Similar to FATCA & Exchange of Information

Similar to FATCA & Exchange of Information (20)

More from The International Business Structuring Association

More from The International Business Structuring Association (20)

Recently uploaded

Recently uploaded (20)

FATCA & Exchange of Information