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Common Reporting Standard (CRS) Compliance in British Virgin Islands FIs

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As a financial institution (FI) in the British Virgin Islands, it is essential to understand the requirements of the Common Reporting Standard (CRS) and take necessary steps to comply. This article provides an overview of key dates, steps for compliance, and reporting information.

Key Dates

The following are the crucial dates that FIs in the British Virgin Islands should be aware of:

  • 2016: FIs have been required to determine the tax residency of both new and pre-existing account holders.
  • 31 May 2017: First CRS reporting deadline
  • 30 September 2017 / 30 September 2018: Information about Pre-Existing Lower Value Individual Accounts and Entity Accounts were either first exchanged by these dates, depending on when FIs identify such accounts as Reportable Accounts.
  • 30 April 2019: All existing FIs who have not done so yet are required to register with the International Tax Authority (ITA).
  • First calendar year following the year they became an FI: All FIs established after 18 September 2018 must register by 30 April of this year.

Steps for British Virgin Islands FIs

To comply with the CRS, FIs should take the following steps:

  1. Adapt onboarding procedures for new investors to capture the requisite information that needs to be reported.
  2. Determine the tax residency of both new and pre-existing account holders.
  3. Report the following information to the ITA in respect of each “Reportable Account”:
    • Name, address, jurisdiction(s) of tax residence, tax identification number(s), date and place of birth of each account holder that is a “Reportable Person” (and each of its Controlling Persons, in the case of an account holder that is a Passive NFE).
    • Account number (or functional equivalent).
    • Name and identifying number (if any) of the FI.
    • Certain financial information (e.g. account balance or value and certain gross amounts paid or credited to the account during the relevant reporting period).

Reporting Information

FIs will report through the British Virgin Islands Financial Account Reporting System (“BVIFARS”). The following is an overview of the reporting process:

  1. FIs will report information through BVIFARS.
  2. Information provided by a FI to the ITA via BVIFARS will be exchanged automatically by the ITA to the relevant tax authorities in each participating jurisdiction.
  3. The ITA is required to publish periodically a list of jurisdictions to be treated as participating jurisdictions for the purposes of CRS.

Further Guidance

For further guidance on the CRS, please contact:

  • Conyers
  • Your primary tax advisers

This publication should not be construed as legal advice and is intended merely to provide a brief overview and give general information.