FATCA & CRS Alert 2021-02

Updated CRS FAQs

Updated CRS FAQs


On 06 May 2021, the Luxembourg Tax Authority released an updated version of the CRS FAQs that contains updates and new questions related to Nil Reporting and updated XSD Schemas.

Some of the FAQs that have been updated (i.e. FAQs 1.1, 1.4, 5.1 and 5.3) or added (FAQs 5.13, 5.14 and 5.15) in the document are summarized below:

Nil Reporting:

  • Nil Reporting has been removed from optional provisions for CRS as Nil Reporting is now mandatory for Reporting Financial Institutions (FIs) that have no CRS reportable accounts (FAQs 1.4 and 5.3)
  • Information regarding the new My Guichet approach for submitting Zero value messages (Nil Reports) is included and it is confirmed that Reporting FIs can still use the existing companies for transmissions (namely FUNDSQUARE and SIX PAYMENTS) (FAQ 5.1)
  • Specific note is added for financial institutions that qualify as “Luxembourg Investment Advisors and Investment Managers” treated as Nonreporting FIs for FATCA purposes as per Section IV.C of Annex II of the Intergovernmental Agreement between Luxembourg and the United States. These are advised to be cautious about Nil Reporting for CRS. In the absence of a similar status for CRS, these FIs will be required to submit Zero Value messages as they will be treated as Reporting FIs, although they are exempt under FATCA (FAQ 5.13).


  • Links and details for the updated CRS technical guidance and example XML files are provided (FAQs 1.1 and 5.13)

Updated XSD Schema:

  • Since 6 January 2021 only the updated data message XSD schema version 2.0 is accepted. The pre-validation platform makes it possible to test these new versions. Reporting FIs are requested to contact their transmitter before performing the end-to-end tests with the ACD via the pre-validation environment (FAQ 5.14)
  • List of UTF-8 characters that are allowed in reports is provided (FAQ 5.15)


For Your Reference:

The updated FAQ can be found on the Luxembourg tax authorities` page, here. (PDF; 1.2MB)


Gerard Laures
Tel.: +352 22 51 51 5549
E-mail: gerard.laures@kpmg.lu

Jean Kizito
Associate Partner, Financial Services Tax
Tel.: +352 22 51 51 5492
E-mail: jean.kizito@kpmg.lu

Ulrike Menn
Tel.: +352 22 51 51 5538
E-mail: ulrike.menn@kpmg.lu