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2019 Automatic Exchange of Information (“AEOI”) Reporting Deadline Extension to 30 September 2020 for the Channel Islands

In response to the COVID-19 pandemic, Revenue Jersey and the Guernsey Revenue Service have taken the decision to extend the deadline for Jersey and Guernsey-resident Financial Institutions to file their 2019 Automatic Exchange of Information (“AEOI”) reports from 30 June 2020 to 30 September 2020.

This decision comes after the US IRS announced it would be granting an extension to 31 December 2020 for Model 1 IGA jurisdictions to provide their Foreign Account Tax Compliance Act (“FATCA”) data for the 2019 tax year to the US Competent Authority. 

Similarly, the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes issued an extension for signatories to the Common Reporting Standard (“CRS”) Multilateral Competent Authority Agreement, extending the CRS report filing deadline from 30 September 2020 to 31 December 2020.

Revenue Jersey and the Guernsey Revenue Service nonetheless encourage Jersey and Guernsey-resident Financial Institutions to file their FATCA and/or CRS reports by the original 30 June 2020 deadline where possible to minimise operational and administrative burden.

Jersey

In the event errors are identified in reports submitted early and these are corrected by the new 30 September 2020 deadline, Revenue Jersey have confirmed no penalties will be incurred.

Guernsey

We would highlight that whilst the reporting deadline has been extended to 30 September 2020, the Guernsey Revenue Service have advised that all Guernsey-resident Financial Institutions are still required to register on the Information Gateway Online Reporter (“IGOR”) by 30 June 2020.

In addition to this, as a new CRS schema will be introduced from 1 January 2021, if any changes are required to be made to any returns after this date, it is likely that the new schema will be required to rectify these. As such, Financial Institutions are encouraged to submit the returns as soon as possible to reduce the risk and additional operational burden in rectifying any returns using the new schema.

If you would like to discuss the above or any other tax matters, please contact one of the KPMG contacts listed on this page and we would be happy to assist.