Common Reporting Standard (CRS)

CRS Overview

The Common Reporting Standard (‘CRS’) was developed by the Organisation for Economic Co-operation and Development (‘OECD’) and approved by the OECD Council in July 2014. The aim of CRS is to combat global tax avoidance and improve tax compliance.

CRS requires financial institutions to identify accounts which are held directly or indirectly by persons who are resident for tax purposes in countries or territories other than the jurisdiction in which their financial account(s) is located. The financial institutions must then report certain financial account information in relation to such account holders to their local tax authorities, who automatically exchange that information with tax authorities in other jurisdictions, on an annual basis.

CRS came into effect on 1 January 2016.

Impact on Bank of Ireland and our customers

As a result of CRS, Bank of Ireland is required to obtain, and report to the local tax authorities in the jurisdictions in which we operate, certain information in respect of our customers. The local tax authorities then exchange the information with the tax authorities in various countries and territories who have signed up to participate in the CRS (over 100 countries have signed up to participate).

CRS affects many of Bank of Ireland’s customers, including personal and non-personal/entity customers. We may need to request information or documentation from you (the Bank of Ireland customer) in order to verify your status for CRS reporting purposes. You may be requested to provide information or documentation in the following circumstances:

• as part of the onboarding (account opening) process if you are a new customer;
• if you are an existing customer of Bank of Ireland for whom we don’t hold the necessary information; or
• if you are an existing customer and there is a change of circumstance on your account(s) which may indicate a change in your status for CRS reporting purposes. Examples of this include:
• ROI based account – a change of address from an address in Ireland to an address in a CRS reportable jurisdiction (and vice versa);
• UK based account – a change of address from an address in the UK to an address in a CRS reportable jurisdiction (and vice versa); and
• ROI/UK based account – a change from an address in one CRS reportable jurisdiction to an address in another CRS reportable jurisdiction.

Please note that you may receive more than one request for CRS information if you have multiple relationships with the Bank of Ireland Group.

If you have previously provided information under the Foreign Account Tax Compliance Act FATCA, you may still need to provide additional information for CRS purposes as these are different regulations with different requirements.

It is important that you respond to all requests for CRS information even if you believe you have already supplied it.

Additional references

For more detailed information on CRS, please:

• Read the frequently asked questions;
• Vist the OECD Automatic Exchange of Information Portal which contains more information on CRS.
• Vist the page about CRS on the Irish Revenue Commissioners’ website (if your Bank of Ireland account is located in the Republic of Ireland).
• Visit HM Revenue & Customs ‘International Exchange of Information Manual’, which contains information about CRS, on the Gov.UK website (if your Bank of Ireland account is located in the United Kingdom); and/or
• Consult a professional tax advisor.

Please note that Bank of Ireland cannot provide tax advice.

CRS – Common Reporting Standard: FAQs

CRS Overview

• 1. What is the CRS?

  The Common Reporting Standard (CRS) is a globally coordinated approach to the disclosure of financial account information in respect of individuals and organisations in order to combat tax avoidance and protect the integrity of tax systems. The CRS was developed by the Organisation for Economic Co-operation and Development (‘OECD’) and approved by the OECD Council in July 2014.

• 2. What is the impact of CRS?

  CRS requires financial institutions to identify accounts which are held by persons who are resident for tax purposes in countries or territories other than the jurisdiction in which their accounts are located. The financial institutions must then report certain financial account information in relation to such account holders to their local tax authorities, who automatically exchange that information with the tax authorities in other CRS participating jurisdictions on an annual basis. Over 100 jurisdictions have signed up to participate in the CRS.

• 3. How do I know if I am affected?

  CRS legislation affects both personal and non-personal/entity customers.

  Under the CRS, financial institutions are required to identify customers who appear to be resident for tax purposes in countries or territories other than the jurisdiction in which their accounts are located, and report certain information to the local tax authority. Certain types of entities with controlling persons are who resident for tax purposes in countries or territories other than the jurisdiction in which the entity’s accounts are located are also required to be reported.

  Non CRS reportable customers will also be indirectly affected, as they may need to answer a number of questions to ensure that they are correctly designated as not CRS reportable.

  It is important that you respond to any requests for CRS information received from Bank of Ireland.

• 4. When did the CRS legislation become effective?

  CRS came into effect for financial institutions on 1 January 2016.

• 5. Is Bank of Ireland the only bank to be affected by CRS?

  No. All banks and other financial institutions in participating jurisdictions are required to be compliant with the CRS. However, their approach to adopting the CRS may differ according to the rules adopted by each country in implementing the CRS. Bank of Ireland is committed to being fully compliant with the CRS in all countries in which we operate.

• 6. What does Bank of Ireland have to do to comply with the CRS?

  In order to comply with the CRS, Bank of Ireland is required to:

  • request information from all customers who are opening new financial accounts in order to determine whether they are reportable for CRS purposes;
  • review our existing customer base to identify customers who could be potentially CRS reportable (and contact them to confirm their details) in order to determine whether they are reportable for CRS purposes;
  • monitor accounts for changes in circumstances which may indicate a change in a customer’s status for CRS reporting purposes (e.g. a change of address to or from an address in a CRS reportable jurisdiction); and
  • report details of accounts held by persons who are resident for tax purposes in countries or territories other than the jurisdiction in which their accounts are located, as well as certain entities which are controlled by such persons, to the local tax authorities on an annual basis (who subsequently exchange the information with the tax authorities in other CRS participating jurisdictions). Bank of Ireland may also need to report information about customers who do not provide the required information to us when requested.
• 7. Which countries and territories are participating in the CRS?

  For the most up to date list of countries and territories participating in the CRS, please see the OECD’s CRS website.

• 8. Is CRS applicable to personal or non-personal/entity customers?

  CRS legislation impacts both personal and non-personal/entity customers who hold an account or wish to hold an account with Bank of Ireland.

  Please refer to the appropriate section below for further information.

 

Personal Customers

• 9. Which personal customers are affected by the CRS?

  All new personal customers are required, as part of account opening procedures, to answer questions to confirm whether they are resident for tax purposes in countries or territories other than the jurisdiction in which their accounts will be located. Using this information, the Bank can determine whether the customer is reportable or not for CRS purposes.

  Existing personal customers may also be asked to provide CRS related information in the following circumstances:

  • If there is a change of circumstance on a customer’s account(s) which may indicate a change in their status for CRS reporting purposes (e.g. a change of address to or from an address in a CRS reportable jurisdiction).
  • If an individual’s account information contains any of the following criteria which may indicate that the individual could be considered tax resident in another country, Bank of Ireland may need to request further information or documentation to determine if the customer is reportable under CRS.
  • identification of the individual as a resident of a CRS reportable jurisdiction;
  • current (mailing, residence, post office box or c/o) address in a CRS reportable jurisdiction;
  • one or more telephone numbers in a CRS reportable jurisdiction and no telephone number in the country of the reporting Financial Institution (e.g. a customer who has provided a Spanish telephone number for an account held with Bank of Ireland in Dublin, but no Irish telephone number);
  • standing instructions (other than with respect to a depository account) to transfer funds to an account maintained in a CRS reportable jurisdiction;
  • current effective power of attorney or signatory authority granted to a person with an address in a CRS reportable jurisdiction; and
  • ‘hold mail’ instruction or ‘in care of’ address in a CRS reportable jurisdiction, which is the sole address for the account holder.

  Having one of these criteria does not mean that a customer is CRS reportable, only that the customer needs closer scrutiny so Bank of Ireland may request additional information.

• 10. Why are you asking me for my jurisdiction(s) of tax residence?

  Under the CRS, financial institutions including Bank of Ireland are required to collect and report to local tax authorities information in relation to their customers who are resident for tax purposes in countries or territories other than the jurisdiction in which they hold accounts. The information to be reported includes the customers’ jurisdiction(s) of tax residence and their tax identification number(s) for each jurisdiction.

  If you wish to open a new bank account with Bank of Ireland, or if you are an existing customer and we hold information which may indicate that you could be considered tax resident in another country, we will ask you to certify a number of details about yourself. This process is called “self-certification” and we are required to collect this information under the CRS.

• 11. How do I determine my tax residence?

  This will depend on where you live and your circumstances.

  The rules regarding what makes a person resident somewhere for tax purposes differ according to the various countries/territories. It is not a question of where you pay tax; for example, the number of days spent in the country can be a significant factor in determining tax residence in some countries (such as the Republic of Ireland).

  You can be considered tax resident in one country/territory and pay tax in another. For example, you may be tax resident in the Republic of Ireland but pay tax in the UK and vice versa.
  If you have any further queries regarding how to determine your tax residency, please:

  • visit the page on the OECD Automatic Exchange of Information portal which contains information published by various countries/territories regarding their tax residence rules; or
  • Consult a professional tax advisor.

  Please note that Bank of Ireland cannot provide tax advice. The tax residence rules depend on each customer’s unique circumstances.

• 12. Which countries and territories are participating in the CRS?

  If you are resident for tax purposes in a country or territory other than the jurisdiction in which your account(s) with Bank of Ireland are located, you may be asked to provide Bank of Ireland with additional information or documentation. Bank of Ireland may also be required to report details of your account(s) to the local tax authority on an annual basis.

  Please note that being treated as CRS reportable due to foreign tax residence should not otherwise affect your day-to-day banking service provided by Bank of Ireland.

• 13. What does CRS mean for me if I am not tax resident in a CRS reportable jurisdiction?

  For most personal customers who are not resident for tax purposes in a country or territory other than the jurisdiction in which their financial account(s) with Bank of Ireland are located, CRS has minimal impact. Bank of Ireland may however need such customers to provide self-certifications to confirm their CRS status.

  Once Bank of Ireland has sufficient information/reason to believe that a personal customer is not resident for tax purposes in a country or territory other than the jurisdiction in which their financial account(s) are located, no further action and no reporting is required (unless such a customer’s circumstances change over time, in which case the customer would need to provide Bank of Ireland with updated information so that the Bank could amend its records).

• 14. What happens if a joint account is held by a CRS reportable person and a non-CRS reportable person?

  A joint account which has one owner who is tax resident in a CRS reportable jurisdiction is treated as a reportable account and the details of the joint account holder who is tax resident in a CRS reportable jurisdiction are included in CRS reporting.

  The joint account holder who is not tax resident in a CRS reportable jurisdiction does not have their personal details (such as name and address) included in CRS reporting. However, the total account balance held by both parties to the joint account must be included as well as the total of any amounts paid or credited to the account during the reporting period (such as interest, dividends etc. – see FAQ 17 for details of the amounts to be reported depending on the account type). This means that the account balance and amounts paid or credited to the account are not split among the joint account holders for CRS reporting purposes.

• 15. How often will I need to provide information for CRS purposes?

  CRS is an ongoing information gathering and reporting process.

  If you have previously provided Bank of Ireland with your CRS information, you are required to notify the Bank if there is any subsequent change to that information.

  If you are an existing customer, and have never previously been asked to provide CRS information, we may contact you to obtain additional information or documentation in order to confirm your CRS status as we are required to review our existing customer base to identify customers who could potentially be CRS reportable. This could also occur where your account information is subjected to any changes which would give the Bank reason to believe that you may be resident, or no longer resident, for tax purposes in a CRS reportable jurisdiction (for example, a customer changing their address to or from a foreign address).

• 16. Why is Bank of Ireland providing tax authorities with my account information?

  As a result of CRS related legislation and regulations, financial institutions (including Bank of Ireland) are legally required to obtain, and report to tax authorities, certain information in respect of their customers.

• 17. What information will Bank of Ireland report to the local tax authority?

  Where a personal account holder is found to be CRS reportable, financial institutions must generally report the following information to the local tax authority:

  • The account holder's name, address and Tax Identification Number (TIN);
  • The account holder's date and place of birth (in certain circumstances);
  • The account holder's jurisdiction(s) of tax residence;
  • The account number or functional equivalent;
  • The account balance or value at the end of the reporting period;
  • The closure of the account (if it has been closed during the reporting period);
  • The following amounts paid or credited to the account (depending on the account type) during the reporting period:
  • With respect to depository accounts, the total gross amount of interest;
  • With respect to custodial accounts, the total gross amount of interest, dividends, other income and proceeds from the sale or redemption of financial assets; and
  • With respect to other accounts, the total gross amount paid or credited to the account including the aggregate amount of any redemption payments.

  The reporting to each local tax authority will take the form of an annual CRS return.

 

Non-Personal/Entity Customers

• 18. What non-personal/entity customers are impacted by CRS?

  All new non-personal/entity customers are required, as part of account opening procedures, to confirm their classification/status for CRS reporting purposes.

  Existing non-personal/entity customers may also be asked to provide CRS related information. If a customer’s account information contains certain criteria, Bank of Ireland may need to request further information or documentation to determine if the customer is reportable under CRS. For non-personal/entity customers the criteria usually include:

  • place of incorporation or residence in a CRS reportable jurisdiction;
  • current (mailing, residence, post office box or c/o) address in a CRS reportable jurisdiction; or
  • indication that the controlling persons (only in relation to certain non-personal/entity customers) may be tax resident in a CRS reportable jurisdiction.

  Having these criteria does not mean that the entity is CRS reportable, only that the customer needs closer scrutiny so Bank of Ireland may request additional information.

• 19. What do I need to do as a non-personal/entity customer?

  In order to establish your status for CRS purposes, we may need you to provide information or documentation, such as Bank of Ireland’s self-certification form. If you are a new customer, you will be asked to provide the CRS information as part of the onboarding (account opening) process. We will also be communicating with affected existing customers that need to provide such documentation, detailing when it will need to be provided by.

  See the forms section for details of the forms accepted by Bank of Ireland for CRS purposes.

• 20. How often will I need to provide information for CRS purposes?

  CRS is an ongoing information gathering and reporting process.

  If you have previously provided Bank of Ireland with the CRS information for your entity, you are required to notify the Bank if there is any subsequent change to that information.

  If you are an existing non-personal/entity customer, and have never previously been asked to provide CRS information, we may contact you to obtain additional information or documentation in order to confirm your entity’s CRS status as we are required to review our existing customer base to identify customers who could potentially be CRS reportable. This could also occur where your entity’s account information is subjected to any changes which would give the Bank reason to believe that your entity may be CRS reportable, or no longer CRS reportable (for example, an entity changing its address to or from a foreign address).

• 21. Under what circumstances would Bank of Ireland need to report CRS information about my account to the local tax authority?

  Bank of Ireland is required to report CRS information to the local tax authority in respect of all accounts held by:

  • customers who are resident for tax purposes in a CRS reportable jurisdiction; or
  • certain entities (Passive NFEs or an Investment Entities which are located in a Non-CRS participating jurisdiction) with controlling persons that are resident for tax purposes in a CRS reportable jurisdiction.

  Please refer to the glossary (ROI-Glossary-business customers ) for the definitions of Passive NFE, Investment Entity and controlling persons.

  In addition, Bank of Ireland may also need to report information about customers who do not provide the required documentation to us. For example, where Bank of Ireland identifies any of the criteria outlined at FAQ 18 above, but the customer does not provide the requested self-certification form to confirm their information, Bank of Ireland may be required to include them in CRS reporting on the basis of the identified criteria.

• 22. What CRS information will Bank of Ireland report to the local tax authority?

  The information reported to local tax authority will depend on the CRS classification of the customer.

  Where a non-personal/entity customer is found to be CRS reportable, financial institutions must generally report the following information to the local tax authority:

  • The account holder's name, address and Tax Identification Number (TIN);
  • The account number or functional equivalent;
  • The following amounts paid or credited to the account (depending on the account type) during the reporting period:
  • With respect to depository accounts, the total gross amount of interest;
  • With respect to custodial accounts, the total gross amount of interest, dividends, other income and proceeds from the sale or redemption of financial assets; and
  • With respect to other accounts, the total gross amount paid or credited to the account including the aggregate amount of any redemption payments.
  • The account balance or value at the end of the reporting period;
  • the closure of the account (if it has been closed during the reporting period); and
  • in relation to an account holder who has been identified as a Passive NFE, or Investment Entity in a non-CRS participating jurisdiction, with controlling person(s) that are resident for tax purposes in a CRS reportable jurisdiction;
  • the name, address, Tax Identification Number (TIN) and date and place of birth (in certain circumstances) of the controlling person(s).

  The reporting to the local tax authority will take the form of an annual CRS return.

  Please refer to the glossary (ROI-Glossary-business customers ) for the definitions of Passive NFE, Investment Entity and controlling persons.

 

What do I need to do?

• 23. What types of information and/or documents can I expect to supply to Bank of Ireland?

  You can complete the FATCA and CRS Self-Certification form online.
  Personal customers - FATCA and CRS Self-Certification form
  Business customers - FATCA and CRS Self-Certification form

  When making requests from affected customers, Bank of Ireland will provide full details of the information and documentation needed for CRS purposes.

• 24. Will Bank of Ireland supply me with all the forms I need to complete?

  Yes. If Bank of Ireland requires CRS information from you, we will either provide you with the relevant forms or direct you to a website where you can download them or submit online versions.

  See the forms section (Link TBC) for details of the forms accepted by Bank of Ireland for FATCA purposes.

• 25. The information I have been asked for on the forms is similar to the information I previously provided for FATCA purposes. Why is this different?

  Even if you have already provided information under the Foreign Account Tax Compliance Act (FATCA), you may still need to provide additional information for the CRS as these are different regulations with different requirements.

  For further details on FATCA, please click here.

  It is important that you respond to all requests for information in respect of both FATCA and CRS even if you believe you have already supplied it.

• 26. When do I have to provide the requested CRS information and/or documentation?

  In general, new customers should supply the requested documentation and information at onboarding (account opening) stage and existing customers should supply it by the date specified in the communication received from Bank of Ireland.

• 27. Why has my other bank requested different CRS documentation than Bank of Ireland?

  The way in which banks and other financial institutions collect CRS information from their customers may vary. This may mean that in some instances you are asked for different documentation from Bank of Ireland than from another bank.

• 28. Where/how should I send requested information and/or documentation for CRS?

  In general, customers should send the requested documentation and information according to the instructions outlined in the communication received from Bank of Ireland.

• 29. What happens to my CRS information that is submitted to Bank of Ireland?

  All customer data is safely stored by Bank of Ireland in accordance with relevant data protection requirements. Our online self-certification forms are secure for the transmission of data.

  Depending on the answers provided to the CRS questions on the self-certification form, a customer may be considered CRS reportable or not. If not, the self-certification form is simply stored as evidence of their non-reportable status. If deemed reportable, the self-certification form is again stored to record their status, but such customers’ financial account information may also need to be reported to the local tax authorities (who may exchange it with the tax authorities in other jurisdictions).

  We will only disclose your information to the relevant tax authorities if we are legally required to do so. Tax authorities who receive the information must also ensure that your data remains confidential.

• 30. Am I allowed to determine which CRS data is going to be reported by Bank of Ireland?

  No. What needs to be reported to the local tax authorities is determined by law.

• 31. What will Bank of Ireland do if I do not provide the information required under the CRS?

  Bank of Ireland may not open new accounts or offer additional products and services to customers who choose not to comply with requests for documentation to establish their CRS status.

  Bank of Ireland may also need to report details of existing customers who do not provide the required CRS information to us on the basis of the information and documentation we hold in our possession. We therefore ask our customers to respond to any requests to properly document themselves for CRS purposes so that we can apply the correct CRS status upon reporting. This is also an opportunity for our customers to update their personal data.

• 32. I no longer have an account with Bank of Ireland; do I still need to provide CRS information?

  Bank of Ireland may be required to confirm whether your account is reportable for CRS purposes even it is has been closed. If a reportable account is closed during a reporting period, its details need to be included in Bank of Ireland’s CRS return for that period. It is important that you respond to all requests for CRS information even if you believe you have already supplied it or the account has since been closed.

• 33. What is a TIN and where can I find mine?

  A Taxpayer Identification Number (TIN) is a unique combination of letters and/or numbers which are assigned by tax authorities to identify tax payers. Some countries do not issue a TIN, but may rely on other issued numbers such as social security/national insurance numbers or company registration numbers for entities. You may need to provide these to Bank of Ireland if requested.

  If you have any further queries regarding how to identify your TIN, please:

  • visit the page on the OECD Automatic Exchange of Information website which contains TIN information published by various countries/territories; or
  • consult the local tax authority in your jurisdiction of tax residence.
• 34. I’m not sure how to complete the documentation requested by Bank of Ireland. What should I do?

  Please note that Bank of Ireland is unable to provide tax advice. Please refer to FAQ 36 (Where can I find further information regarding CRS?) for details of further information sources in respect of CRS.

• 35. My CRS information has changed or I previously submitted incorrect details - can I change these?

  If your previously submitted CRS information is now incorrect or out of date, you must notify Bank of Ireland by submitting a revised self-certification form.

• 36. Where can I find further information regarding CRS?

  If you have any further queries regarding CRS, please:

  • Vist the OECD Automatic Exchange of Information Portal which contains more information on CRS.
  • Vist the page about CRS on the Irish Revenue Commissioners' website (if your Bank of Ireland account is located in the Republic of Ireland).
  • Visit HM Revenue & Customs ‘International Exchange of Information Manual’, which contains information about CRS, on the Gov.UK website (if your Bank of Ireland account is located in the United Kingdom); and/or
  • Consult a professional tax advisor.

  Please note that Bank of Ireland cannot provide tax advice.