The government of the British Virgin Islands ("BVI") has issued a press release advising all BVI reporting Financial Institutions that it will be adopting a relaxed approach to the 1 June deadline for enrolling on the BVI Financial Account Reporting System ("BVIFARS") and that any reporting Financial Institution which enrols prior to 30 June 2015 will not be subject to enforcement action. Reporting Financial Institutions are required to enrol on BVIFARS by this date if they will be reporting information to the BVI International Tax Authority ("ITA") in 2015, in order to comply with their obligations under US FATCA.
Reporting Financial Institutions will also be permitted to report after the initial deadline of 30 June 2015, and, provided such reporting is submitted to the ITA before 31 July 2015, the reporting Financial Institution will not be subject to enforcement action in the BVI.
In addition, it has been decided that the deadline for notifying the ITA of an election to use the alternative reporting regime under UK FATCA ("ARR") will be extended from 31 May 2015 to 30 September 2015. While the press release states that UK Resident Non-Domiciled individuals who wish to use the ARR should submit their elections to the relevant reporting Financial Institution(s) by 28 September 2015, it is recognised that reporting Financial Institutions may determine that the election should be made by an earlier date, provided they notify their clients in advance of this decision.