The Revenue Commissioners have today, 16 May 2017, issued detailed user guides on automatic exchange of information reporting requirements for Irish financial institutions covering both FATCA and CRS/DAC2 reporting obligations.
The new guidelines set out in detail the process for filing FATCA and CRS/DAC2 returns, including the new functionality for submitting ‘nil’ returns.
Financial institutions should note that the registration process for FATCA and CRS/DAC2 reporting is different to that for FATCA reporting in previous years. Reporting financial institutions should take steps to ensure that they are registered for FATCA and CRS/DAC2 reporting as soon as possible, in advance of the filing deadline of 30 June 2017.
Separately, the European Commission has identified and notified Member States of an issue within their validation module for CRS/DAC2 which requires updating and as a result, the Revenue Commissioners have closed the CRS/DAC2 filing portal temporarily. The portal for filing FATCA returns remains open. The Revenue Commissioners have indicated that they will issue an update on this next week.
To the extent that you have any queries in relation to the content of this briefing, please feel free to contact a member of our Tax Department.