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  • Elizabeth A. McMorrow

BVI Primary User Must Have A Permanent Position Within FI

The British Virgin Islands (BVI) International Tax Authority (ITA) recently reminded Financial Institutions (FIs) that the BVI Mutual Legal Assistance (Tax Matters) Act (MLA) requires that a BVI FI’s registered Primary User must have a permanent position within the FI.

The MLA permits the FI to use an agent to undertake the FI’s CRS duties and obligations but this agent can only be a Secondary User not the Primary User in the BVI Financial Account Reporting System (BVIFARS) portal.

When the FI is registered in the BVIFARS portal, it is necessary to identify the person who will be the principal point of contact as the Primary User. Data fields must be completed providing the Primary User’s name, address, email address, and phone number. The Primary User may name up to three Secondary Users in the BVIFARS portal. These individuals may have a permanent position within the FI or be outside service providers. However, it is the Primary User who is responsible for managing all Secondary Users.

If the BVIFARS portal registration for your BVI FI currently lists an outside agent rather than an individual with a permanent position within your BVI FI, you must update the registration by December 31, 2022. The ITA warned that failure to update the registration by the deadline is an offense under the BVI CRS Legislation.

For details how to navigate the BVIFARS portal, check out the BVIFARS User Guide.

The ITA did not provide an update regarding the date it will implement its new BVIFARS user fee.

For assistance, please contact me via my contact page or at

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