Timetable: CDOT to CRS Transition Detailed Guidance
CDOT to CRS Transition, detailed guidance
The first reports under the CDOT IGAs happen in 2016 in respect of both of the years 2014 and 2015, with different due diligence for pre-existing accounts (and hence different accounts and details from accounts) applying to each year. Reporting in 2017 for the 2016 calendar year will then add the final details.
The first report in 2016 under the CDOT IGAs will include:
- All new accounts opened after 1 July 2014 (subject to reporting thresholds [see IEIM402565]; and
- Pre-existing high value individuals’ accounts as the due diligence for such accounts must have been completed by 30 June 2015 (as set out in Article 3 and Annex 1 to the IGAs).
- Those pre-existing lower value individual accounts and pre-existing entity accounts that have been identified as reportable in 2014 or 2015.
Once identified as reportable accounts, these accounts continue to be reported annually thereafter, subject to account closure or a change of circumstance making them non-reportable.
For the remaining pre-existing accounts the due diligence procedures must be completed by 30 June 2016 in preparation for first reporting in 2017.
The first reports under the CRS happen in 2017 and will include:
- All new accounts opened on or after 1 January 2016;
- Pre-existing high value individuals’ accounts in existence at 31 December 2015 that have not been previously identified as reportable accounts under the CDOT IGAs; and
- Any other reportable accounts that are identified as reportable in 2016, including closed accounts which were open at the end of 2015.
The transition in 2016, 2017, and 2018
The due diligence processes Financial Institutions carry out in 2016 may be under both the IGAs and the CRS, as the due diligence procedures under the IGAs do not need to be fully completed until 30 June 2016 while the CRS procedures commence on 1 January 2016. As indicated above, HMRC will only require the data to be reported once whichever regime identifies the account as reportable, and reporting can be done in 2017 using the CRS schema.
2017 is the year where there is overlap between reporting under the IGA and the CRS.
From 2018 onwards, reporting is purely under the CRS.
For 2017, as set out above, what should be reported is the maximum of what is required by the CRS or the IGA for that year. This meets both the purpose of the IGAs and the CRS.
This means that the accounts which need to be reported in 2017, in addition to what is required under the IGA, are those accounts identified as reportable under the CRS but not reportable under the IGA. These will include, for example, accounts where an election has been made to exclude accounts below a specified amount from review, identification and reporting under the IGA [see IEIM402570].
For new accounts opened on or after 1 January 2016, Financial Institutions may rely on CRS due diligence processes to identify Specified CDOT Persons.
All accounts identified as reportable by 31 December 2016 must be reported in 2017 irrespective of the regime under which they were identified.