Governments around the world are sharing information amongst between each other at an ever increasing rate. One example of an information exchange regime falls under legislation known as the Common Reporting Standard (CRS) which is seen as a critical tool in the worldwide fight against tax evasion.
To date more than 100 jurisdictions have committed to adopting the CRS. These include countries such as the UK as well as areas that are subject to their own distinct tax regulations such as Jersey, Guernsey, Isle of Man etc. Any reference to countries in the following FAQs relates to all jurisdictions who have committed to adopting the CRS.
To comply with the CRS, Financial Institutions must obtain certain personal information from customers, before then providing it in specific circumstances, on an annual basis, to their local tax authority. In turn, the local tax authority will then exchange this information with overseas tax authorities where the country has formally signed up to participate.
In Jersey, Guernsey and the Isle of Man, we are required to complete CRS reporting to the Tax Authorities in each respective jurisdiction by 30 June every year in respect of customers we have identified as Reportable Persons or Reportable Entities.
How does the Common Reporting Standard impact me?
Under the CRS, Lloyds Bank Corporate Markets Plc and its branches are required to identify customers who hold accounts in the jurisdictions in which it operates who are tax resident in another different country outside of that jurisdiction for inter-country reporting purposes. To do this we need to collect information from customers and report certain information on any Reportable Persons and Reportable Entities and their Financial Account(s) to the local tax authorities where their account is held. This information will then be reported onwards to the tax authorities of the countries in which customers are tax resident.
Customers who are only tax resident in either Jersey, Guernsey or the Isle of Man and hold their accounts within the same jurisdiction where they are tax resident are likely not to need to do anything as they will be identified as resident for tax purposes in the Island where they live together with their account and therefore not a Reportable Person or Reportable Entity. However, there will be some customers who based on the information we hold, we believe to be Reportable Persons or Reportable Entities.
If we feel we need further information we will write to you asking you to complete a Tax Residency Self-Certification form. In some cases we will ask you for a reasonable explanation and/or additional documentary evidence as proof of tax residency. We may also write to you asking you to contact us so we can update the information we hold on you such as your Tax Identification Number (TIN) e.g. Unique Taxpayer Reference or National Insurance Number, confirmation as to where you are tax resident or your date of birth.
A list of jurisdictions is available on the Organisation for Economic Co-operation and Development (OECD) website providing an overview of domestic rules in the jurisdictions listed governing the issuance, structure, use and validity of TINs or their functional equivalents.
Do I need to do anything?
If you are affected by the CRS we may write to you asking you to fill in a Tax Residency Self-Certification form or call us to advise on missing information.
What does the Common Reporting Standard mean for customers?
Lloyds Bank Corporate Markets Plc and its branches are obliged to report to the local tax authority the customers with a Financial Account who are tax resident in one Reportable Country but with Financial Accounts held in another. The local tax authority will then pass this information onto the Reportable Country where it has been established, or is believed due to information held, that the customers are resident for tax purposes.
Where can I find out more about the CRS?
In the first instance, you may like to look at the Organisation for Economic Co-operation and Development’s (OECD) website where more in-depth technical information have been published by each national tax authority. There has been significant coverage on CRS and there are many information resources available, including through the tax authorities in the country or jurisdiction where you are tax resident.