Germany: Updated CRS guidance concerning refugees from Ukraine

Updated information concerning CRS regime and implications for refugees from Ukraine

Updated information concerning CRS regime and implications for refugees from Ukraine

Germany’s federal central tax office (BZSt) released guidance (CRS Newsletter 03/2022) with updated information concerning the common reporting standard (CRS) regime and implications for refugees from Ukraine.

The updated information provides a decree of “no objection” for refugees from Ukraine who open an account without providing a self-certification within 90 days, beginning on 16 March 2022. Financial institutions opening an account must obtain the self-certification of the account holder that, in principle, includes a tax identification number to determine the residence. If it is not possible to obtain the self-certification, then the financial institution needs to attest that obtaining self-certification is impossible for legal or factual reasons.

The BZSt recognizes that the ongoing war in Ukraine is an actual reason for not being able to procure the self-certification. Thus, it may still be impossible for refugees to complete their self-certification beyond the given 90 days. In this scenario, failure to provide self-certification by persons who have fled Ukraine is not objectionable for the time being, and lack of documentation will not lead to any disadvantage for them.

Read a March 2022 report [PDF 474 KB] prepared by the KPMG member firm in Germany


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