As tax specialists will already know, operational taxes are a
crucial area for compliance matters nowadays. Broadly speaking,
they encompass withholding taxes, transactional taxes, due
diligence, and tax and investor reporting. In this article, we look
at these requirements under the FATCA and CRS regimes. Keep reading
for our 5-question checklist, designed to help you determine how
compliant you are with FATCA and CRS.
1. Pre-existing accounts
Have you completed the FATCA and CRS remediations of
pre-existing accounts?
The remediation period for entities was two years under both
FATCA and CRS. In other words, reporting financial institutions had
two years from the go-live of FATCA and CRS to conduct the
necessary due diligence procedures for pre-existing accounts. They
should now ensure that their reporting and policy documentation,
for recalcitrant and undocumented individuals or entities, are
treated properly.
