Ireland: Updated filing guidelines for FATCA

The guidelines update certain sections in the Tax and Duty Manual.

The guidelines update certain sections in the Tax and Duty Manual.

The Irish Revenue Commissioners published updated filing guidelines for FATCA.

The guidelines—Tax and Duty Manual Part 38-03-25—includes updates to the following sections:

  • Section 7.6 “XML Schema Element Reference-TIN” was updated to include additional guidance on the reporting of accounts with no U.S. tax identification number (TIN). In particular, in order to better understand the reasons why a foreign financial institution in a Model 1 IGA jurisdiction may not have been able to obtain a U.S. TIN, the U.S. tax agency (IRS) developed a series of codes that may be used by an foreign financial institution to populate the U.S. TIN field when a U.S. TIN is not available. These codes may be used as an alternative to enter nine consecutive capital letter “A” (AAAAAAAAA). The use of these codes is optional and does not mean that an foreign financial institution will not be at risk of being found significantly non-compliant due to a failure to report each required U.S. TIN.
  • Section 7.11 “Pooled Reporting” was added to clarify that pooled reports may not be submitted by foreign financial institutions in a Model I IGA jurisdiction; and therefore, pooled reporting is not permitted in Ireland. Any files with pooled reporting will be rejected.
  • Section 7.12 “Correcting, Voiding and Amending FACTA Submissions-Sample XML Files” was added to clarify the general rules that must be followed when correcting, voiding or amending FATCA submissions and also includes links to sample corrected, voided and amended XML files for ease of reference.
  • Section 7.13 “Passive NFFE which is not a US Entity” was added to provide guidance on how to populate the “TIN” and “TIN Issued By” fields in the FATCA XML scheme for a passive non-financial foreign entity with a U.S. controlling person.

Read a May 2021 report [PDF 738 KB] prepared by the KPMG member firm in Ireland



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