Obligations under automatic exchange of financial account information (AEOI) regimes will increase over the next few months in many jurisdictions, as the US Financial Accounts Tax Compliance Act (FATCA) and the first year of the Common Reporting Standard (CRS) proceed. Each jurisdiction may have a different timetable for its domestic reporting procedures. Investment funds and managers should be aware of the legal requirements. These are three of the latest jurisdiction-specific updates:

• In the UK, the deadline for submitting AEOI returns for the year ended 31 December 2016 is 31 May 2017. Returns should include reportable accounts for FATCA, Crown Dependencies and Overseas Territories (CDOT) reporting and the first year for CRS. More information on the requirement to register and submit can be found in HMRC’s AEOI guidance.                                        
• In Ireland, FATCA and CRS reporting for 2016 is due to be filed electronically with the Irish Revenue via the Revenue On-Line System (ROS) by 30 June 2017. Filing Guidelines for FATCA and CRS  detail the filing process from registration of the Financial Institution as a reporting entity under both FATCA and CRS through to completion and filing of the returns, including detail on the new filing facility for submitting ‘nil’ returns via the ROS.
• In the Cayman Islands,  the Department for International Tax Cooperation (DITC) has published updated AEOI portal guidance (AEOI Portal User Guide v3.1 (User Guide)) which explains how Cayman Financial Institutions must perform their notification obligations in respect of US FATCA and the CRS. It also describes how they should comply with reporting and further obligations under US FATCA. In relation to CRS reporting, the DITC will issue a further industry advisory in mid-June to confirm the publication of a revised version of the User guidance with details on CRS reporting. The CRS reporting function is available on the AEOI portal. which was reopened on 17 May. CDOT reporting will be combined with CRS reporting. The deadline for CRS notification is 30 June 2017 and for CRS reporting in respect of 2016 is 31 July 2017.

For further information, please contact Paul Hale or Enrique Clemente.