The Common Reporting Standard
Important Tax Co-operation and Disclosure Information
The Isle of Man and the evolution of the Common Reporting Standard
The Isle of Man has long been committed to tax transparency and in 2013 signed
Intergovernmental Agreements (IGAs) with both the US and UK to improve international
tax compliance by automatically exchanging financial account information with those
jurisdictions from 2015 and 2016 respectively. The automatic exchange of financial
account information is about improving transparency in the fight against cross-border tax
evasion and in so doing protecting the integrity of the tax systems of the participating
The Isle of Man/UK IGA contained a mutual commitment to continue to enhance the
effectiveness of information exchange and transparency with both jurisdictions making a
commitment to the development of the Common Reporting Standard (CRS). CRS quickly
became the new global standard for automatic exchange of financial account information
reported to governments by financial institutions and covering financial accounts held by
individuals and entities for taxation reporting purposes. Developed by the Organisation for
Economic Co-operation and Development (OECD) at the request of the G20, CRS builds
on the US Foreign Account Tax Compliance Act (FATCA).
Currently over 90 jurisdictions have now made a commitment to the implementation of the
CRS and as an ‘early adopter’ the Isle of Man will make its first exchange of information in
respect of the 2016 calendar year, in September 2017.
CRS requires financial institutions in participating jurisdictions, such as PBI, to obtain and
report information to local tax authorities on an annual basis. Therefore, financial
institutions in CRS participating jurisdictions, such as the Isle of Man, have to identify
reportable persons (either individuals or entities) holding reportable accounts who are
resident for tax purposes in other CRS participating jurisdictions.
CRS came into effect on 1st January 2016.
For further information on CRS please refer to the below website:
How CRS impacts Permanent Bank International (PBI) Customers
Accounts held as at 31st December 2015 are subject to a CRS due diligence requirement
in order to identify reportable persons. Account holders will be regarded as a resident of a
reportable jurisdiction, requiring the completion of a self-certification, if any of the indicia
- Identification of the account holder as a resident of a reportable jurisdiction
- Current reportable jurisdiction mailing or residence address (including a PO Box address)
- Current reportable jurisdiction telephone number
- Current effective power of attorney or signatory authority granted to a person with a reportable jurisdiction address
- A “care of” or “hold mail” reportable jurisdiction address that is the sole address PBI holds for the account holder
If none of the above indicia are discovered, no further action is required unless and until
there is a subsequent change in circumstances that results in one or more of the above
indicia being associated with the account, or the account holder, in which case the account
holder becomes a reportable person and the account becomes a reportable account, so
the necessary self-certification documentation will be required.
CRS requires all new individual and entity account holders, as of 1st January 2016, to
complete a self-certification providing their tax residency as part of the application process
and (where appropriate) their Tax Identification Numbers (TINs). This has been
incorporated into the application form.
If any of the required documentation is not provided, account information could be
reported to the local tax authority, who may in turn share that information with other
relevant tax authorities in CRS participating jurisdictions. If this later proves to be incorrect
then PBI will not be liable in any way for any direct losses, indirect losses, consequences,
resulting investigations or costs as a result of such reporting. In any circumstances PBI will
not be liable for any loss (direct or indirect) as a consequence of it fulfilling its
responsibilities under CRS or any other regulatory or statutory requirement.
Having identified the tax residency of those customers in participating jurisdictions (both
individuals and entities), PBI is obliged to collect information (i.e. name, address,
jurisdiction(s) of residence, TIN(s) and date of birth/date of incorporation/date of
establishment) and report it together with account information (i.e. account number,
currency and account balance at the end of each reportable year) to the local tax authority,
who in turn will share this information with other relevant tax authorities in CRS
This information is based on laws and guidance which may be subject to change in content and interpretation. It is for guidance purposes only, so it is not comprehensive and does not constitute legal or tax advice. Account holders should consult their own professional advisers as to the implications of the Common Reporting Standard (CRS).
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