Putting “U” into AEoI

Phil Morris Tax Director April 07, 2017

The first reporting deadline for the Automatic Exchange of Information (AEoI) in the Isle of Man is now three months away (30 June 2017) and businesses should be thinking about their reporting obligations and how they are going to do this, if they have not already done so.

Whilst many businesses may feel better prepared with a few years of FATCA reporting under the belt, many may feel that there is still a lot of work to do and the clock is ticking. It is helpful to consider the process for successful compliance.

Everyone will have a different approach when looking at an implementation project to be prepared for AEoI reporting and whilst there isn’t necessarily a “one size fits all” solution, you could start by asking yourself some simple questions.

Do you know who is impacted?

By identifying how entities are classified, you can then determine what their obligations are and where these obligations exist. They may only need to complete a self-certification or they may need to collect information on their client base to be in a position to undertake reporting.  You don’t want the obligations to be any more difficult than they need to be.

Do you have a Project approach?

Securing the required project resources including budget, staff, time and infrastructure provides the framework for dealing with the project. Perhaps easier said than done though.

What can you learn from FATCA?

Whilst FATCA and AEoI are similar, they are not identical. There are many things you can learn from FATCA implementation and build from this.  By identifying what went well and not so well, you can consider how the differences impact and how they are dealt with.

Are you getting IT right?

Information technology is likely to be a critical aspect for the project in terms of identifying the necessary information and being in a position to report. You should be checking to ensure that your existing IT systems and client management databases do what you need them to do and identify what, if any changes may be required.

Do you need to amend your documentation?

AEoI will impact many aspects of procedures, legal and regulatory documents. There will be a lead time to review, update and finalise the necessary documents.  For instance, do your Terms of Business mention FATCA and AEoI?

How are you handling the “customer experience”?

Dealing with notification requirements and how you manage the client relationship will be important. You should try to keep terminology simple; don’t unnecessarily overcomplicate self-certification forms and think about how you are going to let people know that you may be reporting on them. Keeping it simple and understandable is challenging, but key.

Finally, are you in control?

Once you have been through a review and implementation, you should think about how you are going to test and monitor on an ongoing basis to check effectiveness.

At PwC, we have been helping many Financial Institutions and their customers to understand the impact and their obligations. This has included undertaking impact assessments, providing AML/KYC solutions and remediation, helping to shape culture and conduct changes, supporting customer conversations and providing information reporting capability. Now is the time to focus and get everything in place.

Phil Morris, Tax Director, PwC Isle of Man

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Phil Morris
Tax Director
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