Timetable: CDOT to CRS Transition
CDOT to CRS Transition
Reporting under the Crown Dependency and Overseas Territories (CDOT) arrangement will begin in 2016 for information relating to the years 2014 and 2015; for the Crown Dependencies and Gibraltar the arrangements are reciprocal, so the UK will need to provide data on the residents of these jurisdictions. In 2017 the UK and all of the Crown Dependencies and Overseas Territories will adopt the CRS. Current non-reciprocal arrangements will continue, except in the case of Montserrat which will change to a reciprocal basis.
There are items that would be reportable under the CDOT arrangement for 2017 which are not within the CRS, and terms within the CRS which would lead to more reporting than under the CDOT arrangement. In order to ease the transition, arrangements will be put in place to ensure that, while there is overlap in the period covered by the IGAs and the CRS, there is no need for duplicate reporting. The rule to follow will be that wherever the IGA or the CRS requires more reporting in the transition year of 2017, then the “more” should be reported.
- In 2017 the CRS does not require reporting of lower value pre-existing individual accounts and pre-existing entity accounts unless identified. The due diligence processes to identify these can run until 31 December 2017; the due diligence required by the IGA for these accounts will have been completed, consequently all CDOT reportable lower-value pre-existing accounts will need to be reported in 2017.
- What should be reported in respect of low value accounts in 2017 is therefore what is required under the IGA since that is “more”; where the accounts would be reportable under both regimes the report under the IGA will satisfy the requirement to report under the CRS.
The practical effect of this approach is that for 2016, reporting is done under the IGA requirements. For 2017, there is a mix under IGA and CRS requirements. Then, from 2018 onwards it is just the requirements of the CRS that apply. However, at no time will there be a need to report the same thing twice. Where Reportable Accounts have been identified and reported under the IGA, they will be deemed to have been identified and reported for the purposes of the CRS. To achieve this we will be amending the UK implementing legislation to make provision for this deeming. We will be recommending the other jurisdictions involved to do likewise.
There will be one AEOI Schema, which will allow for reporting under either the IGAs or CRS and should help with this approach.