CRS Reporting Obligations: Tax Identification Numbers (TINs)

Document Overview

An explanatory note clarifying the mandatory reporting of Tax Identification Numbers (TINs) under the Common Reporting Standard.

Key Takeaways

• Requires the collection and reporting of TINs for all Reportable Persons (Account Holders and Controlling Persons).
• Confirms that a self-certification is invalid without a TIN, unless the jurisdiction of residence does not issue TINs.
• Mandates FIs to perform reasonable efforts to obtain TINs for Pre-existing Accounts annually if missing.

Key Concepts Covered

• Common Reporting Standard (CRS)
• Self-Certification
• Reporting Financial Institution
• Reportable Jurisdiction
• Penalties and Enforcement
• DITC Portal / TIA Portal
• Reportable Account vs. Reportable Person
• Controlling Persons
• Preexisting vs. New Accounts
• CRS vs. US FATCA: Key Differences

Deadlines & Timelines Mentioned

• New Accounts (Financial Accounts maintained by a Reporting Financial Institution opened on or after 1 January 2016) The CRS requires reporting of the TIN, or functional equivalent, for all New Accounts, as the TIN must be collected upon account opening in the self-certification.
• Pre-existing Accounts (Financial Accounts maintained by a Reporting Financial Institution as of 31 December 2015) For Pre -existing Accounts, the CRS requires reporting of the TIN , or functional equivalent , in all cases where it is in the records of the Reporting Financial Institution.