Automatic Exchange of Information: FATCA and OECD CRS

The new SARS Business Requirement Specification (BRS) issued on 24 June 2016 is significantly different from the FATCA BRS that has been in existence for the past two reporting periods.  The following are important when completing the new submission to SARS:

• Mandatory indicators in the BRS include TIN Provided Indicator; Identification number Indicator and General Compliance Indicator for the Account Holder;
• Tax Identification Number will become compulsory for FATCA reporting purposes from 2018;
• An account could have dual reporting classifications i.e. reportable for FATCA and CRS purposes;
• A Sponsored Entity does not need to provide its own Global Intermediary Identification Number until 01 January 2017 and is not required to register before that.

Reporting for the period ending 28 February 2017 will not only contain US-related information, but also information on Reportable Jurisdictions which are defined as any jurisdiction other than the United States of America or South Africa.  The information to be reported relates to all new accounts opened from 01 March 2016 as well as information on pre-existing High Value Individual Accounts (being accounts with an account balance equal to or exceeding R15 000 000 as at 29 February 2016).

RC Terblanche (CA)SA, MBA is the former Competent Authority for Exchange of Information at SARS and now a director at CRSMondial and an expert on FATCA and OECD CRS