Common Reporting Standard
The Government of the British Virgin Islands ("BVI") has recently announced an extension to the deadlines for the notification and reporting obligations under the Common Reporting Standard ("CRS"). Under the extended deadlines for CRS, all BVI Reporting Financial Institutions now have until 30 June 2017 to enrol with the BVI International Tax Authority (the "ITA") via the BVI Financial Account Reporting System ("BVIFARS") and to report their reportable accounts via BVIFARS by 31 July 2017.
With respect to US FATCA, the enrolment and reporting deadlines remain unchanged. Accordingly, the enrolment and reporting deadlines for US FATCA are as follows:
(a) All BVI Reporting Financial Institutions that have not previously enrolled with the ITA via BVIFARS should have enrolled by 1 April 2017; and
(b) All BVI Reporting Financial Institutions must report their reportable accounts through BVIFARS by 31 May 2017.
UK FATCA / UK CDOT
UK FATCA (or "UK CDOT") will transition to the automatic exchange of information under the CRS. However, the UK Government has confirmed that for BVI Reporting Financial Institutions whose 2016 accounts are reportable in 2017, both the UK IGA and CRS will be operational. Accordingly, in order to comply with both regimes, BVI Reporting Financial Institutions will be required to report to the maximum of what is required by the CRS or the UK IGA. It is also important to note that the ITA has extended the 31 May UK CDOT enrolment deadline to 30 June 2017 and the reporting deadline has been extended to 31 July 2017 for consistency with the CRS enrolment and reporting deadlines. For 2017 only, all UK CDOT reporting is to be submitted in accordance with the CRS XML Schema.
BVIFARS Open for Enrolments and US FATCA Reporting Only
The ITA has confirmed that BVIFARS has been updated and can now accept US FATCA, UK CDOT and CRS enrolments. However, as it relates to reporting submissions, BVIFARS can only accept US FATCA submissions at this time. We are expecting an announcement from the BVI Government shortly as to when BVIFARS will be ready to accept UK CDOT and CRS reporting submissions.