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Revenue Jersey released a taster last week of what to expect in the upcoming Automatic Exchange of Information (“AEOI”) reporting deadline of 30 June 2020. While we still await the issuance of updated Guidance Notes, we have summarised below the pertinent points.

Firstly, the AEOI portal is now open and Jersey Financial Institutions (“FIs”) that are in a position to file their 2019 FATCA or CRS reports may do so.

AEOI portal registration

Revenue Jersey has prompted how important it is to ensure that an FIs registration details are up to date, particularly the contact details. It is the contact details provided within the registration details that Revenue Jersey will use to:

a)     confirm the reports have been submitted successfully;

b)     to provide updates on any key changes to the AEOI portal; and

c)     contact you should there be any problems with the submitted reports.

Now is the time to confirm your details are correct and up to date!

Validation tool

All Jersey FIs are required to submit their AEOI reports via Revenue Jersey’s online AEOI portal – this option has not changed. However, Revenue Jersey has created more robust validation checks within the portal.

FATCA reporting

All FIs under the FATCA regime should have obtained a Global Intermediary Identification Number (“GIIN”).

FATCA reports will automatically be rejected if a GIIN is not provided or if the FI’s name is not an exact match to the FI name registered with the IRS to obtain a GIIN. A lack of GIIN will not be accepted as a valid excuse for failing to submit the report by the deadline. An FI that needs to report and has not yet obtained a GIIN will need to register with the IRS by early May to be certain of being able to file in Jersey.

CRS reporting

Revenue Jersey is reminding FIs that they have noted errors in reporting Trustee-Documented Trusts (“TDT”) and other Investment Entities (“IE”) correctly. If you are reporting on behalf of a trust or another IE, please refer to the practical guidance notes and Compliance Note 1 (CN1) issued in April 2019. Penalties will be applied if a TDT or IE is incorrectly reported and not corrected before the submission deadline.

TINs

As many of you are aware, Jersey has implemented changes to individual’s and entity’s Tax Identification Numbers (“TIN”). All Jersey individuals and entities have been assigned a new 10 digit TIN. For the purposes of the 2019 AEOI reporting, Revenue Jersey will accept the following TINs:

1)     For individuals, new 10 digit TIN or Jersey social security number;

2)     For entities, the new 10 digit TIN, the old tax reference number or the company registration number.

Please note that although the framework of the law exists requiring certain Jersey FIs to report on Jersey resident account holders, the Jersey regulations have not yet been lodged and so there is no local reporting for this year.

Nil reporting

Many of you will be glad to hear that compulsory nil reporting has been postponed for another year and therefore nil reporting is not mandatory for the 2019 reporting period.

If you would like to discuss the above or any other tax matters, please contact one of the KPMG contacts listed in the right-hand column.