Extension of the FFO Agreement and a Second Version of the Common Reporting Standard for the Automatic Exchange of Information on Financial Accounts

FATCA

Renewal of the FFI Agreement

On June 6, 2017, the IRS communicated that the FATCA Registration System has been updated to enable FFIs to renew their FFI Agreements. 

As mentioned in our PEQ CRS/FATCA/QI Information 02/2017, the IRS issued a new FFI Agreement (Rev. Proc. 2017-16) which requires participating FFIs and FFIs in Model 2 jurisdictions to renew their FFI Agreements. FFIs will use the FATCA FFI Registration System for the renewal of the agreement and should do so before July 31, 2017.

Once timely renewed, the FFI agreement will be deemed to be in effect retroactively as of January 1, 2017.

CRS

Registration with the FTA

As mentioned in our PEQ CRS/FATCA/QI Information 05/2017, the Swiss FTA has launched the CRS registration module on the ESTV SuisseTax portal. 

Since all Swiss financial institutions are expected to register with the FTA by December 31, 2017, financial institutions should be advised to allocate sufficient time to determine their CRS status and CRS status of any group members in order to ensure that all entities are timely registered with the FTA.

New Common Reporting Standard and updated FAQs

The OECD has released the second edition of the Common Reporting Standard which includes an updated CRS XML Schema User Guide. The regulation itself has remained unchanged. 

In addition, the OECD and the Swiss State Secretariat for International Financial Matters (SIF) have recently updated their CRS FAQs with new information.