Navigating the latest Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) updates
The regulatory environment around tax transparency is constantly evolving, and so are the expectations on Financial Institutions. On 2 January 2020, Malta’s Commissioner for Revenue (CfR) had introduced guidelines for FATCA and CRS, merging both frameworks into one comprehensive reference.
At PwC, we’re here to make complex guidance clearer, and help you act on what matters most: accurate, timely and compliant reporting.
What are the main changes to the guidelines?
- Clarified classification of Cell Companies and their reporting obligations;
- The removal of the Holding and Treasury Company Financial Institution category in FATCA.
- Clarification on Distributed Ledger Technology Assets to achieve a more aligned approach with that taken in the Guidelines issued by the CfR for tax purposes;
- A more comprehensive detail on the local FATCA and CRS registration, modifications and cancellation processes;
- Alignment of the definition of passive income with that in the Income Tax Act;
- Rules on Citizenship by Investment / Residence by Investment;
- Changes in deadlines in relation to the “Excel Spreadsheet” submissions;
- More comprehensive guidance on the completion of data elements for reporting purposes;
- Updated information on Recalcitrant and Undocumented Accounts; and
- Updated rules applicable to Trusts in respect to Registration and Reporting by the Trustee to the CfR and the removal of the reference to “professional trustee”.
XML Schema Reporting
FATCA and CRS reporting has now been in place for several years, however, when considering the context of ever-increasing regulatory reporting requirements in general, compiling various reports can be rather challenging.
The guidelines explain that Maltese Financial Institutions can only use the Excel baqsed alternative report if they obtain permission from the CfR. For those Financial
Institutions that are unable to obtain this permission, or in case a Financial Institution has more than 100 Reportable Accounts, the FATCA and CRS reporting the XML Schema becomes mandatory.
At PwC, we facilitate the FATCA and CRS reporting process with our PwC XML Schema Reporting Tool.
This tool is especially designed to help with the population and testing of the information to be included in the FATCA and CRS reporting. Furthermore, the PwC Automatic Exchange of Information Team can also assist you in compiling, collating and reviewing the necessary data in terms of the FATCA & CRS reporting Guidelines.
What does our PwC XML Schema Reporting Tool deliver?
- Identifies any errors before submission to the CfR;
- Supports all types of reportable accounts, including individuals, companies, trusts, foundations, and trustee-sponsored trusts;
- Carries out checks and deliverables using a consistent high standard in line with relevant guidelines;
- Assists with the decision-making process vis-a-vis the the accounts being reported; and
- Flexibly allows full control of the reportable data.
Why should you choose the PwC XML Schema Reporting Tool?
Using our tool, backed by PwC’s Automatic Exchange of Information team, helps you:
- Reduce the risk of compliance delays or CfR queries;
- Submit high-volume reports with clarity and consistency;
- Maintain control while gaining expert guidance when needed; and
- Focus your time where it matters, with confidence in the accuracy of your reporting.
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