On 7 September 2020, the Irish Revenue Commissioners published updated CRS FAQs to add a new FAQ 10 which clarifies what schema Irish Financial Institutions should use to prepare and report information under CRS to the Irish Revenue Commissioners.
In particular, FAQ 10 confirms that CRS XML Schema Version 1.0 and CRS User Guide Version 2.0 are applicable for all exchanges until 31 December 2020. As the CRS filing deadline for the 2019 reporting year has been extended to 30 September 2020, with exchanges between tax authorities taking place in advance of the 31 December 2020 deadline, the CRS XML Schema Version 1.0 and CRS User Guide Version 2.0 should be used for such CRS filings.
The CRS XML Version 2.0 and CRS User Guide 3.0 will be in use for all CRS exchanges from 1 February 2021.
The Irish FATCA and CRS return filing deadline for the 2019 reporting year was previously extended from 30 June 2020 to 30 September 2020.
1.1 Updated Filing Guidelines for FATCA (Tax and Duty Manual Part 38-03-25)
On 31 July 2020, the Irish Revenue Commissioners published updated Filing Guidelines for Foreign Account Tax Compliance Act (FATCA) via Tax and Duty Manual Part 38-03-25.
There were no material changes made to the filing guidelines with the changes simply being made to reflect updated screen shots and language which more closely aligns with the FATCA registration and reporting facilities in ROS.
2.1 Filing Guidelines for DAC2 – CRS (Tax and Duty Manual Part 38-03-26)
The Filing Guidelines for DAC2 – Common Reporting Standard (CRS) are currently unavailable on Revenue’s website, as they are being updated.
2.2 MCAA Signatories
On 3 September, the OECD published a revised list of MCAA Signatories, bringing the total number of signatories to 109.
Should you require any assistance with meeting your reporting obligations under FATCA and CRS ahead of the 30 September 2020 deadline, please contact Kevin Cohen, Head of AEOI.