CRS & FATCA: Guernsey, Isle of Man, Bermuda Extensions
Guernsey announced it has extended both the FATCA and CRS reporting deadlines to September 30, 2020. However, Guernsey made clear that filings submitted after September 30, 2020 may be subject to enforcement action.
You should not put off all Guernsey preparation until later this summer as you must ensure that all of your Reporting Guernsey Financial Institutions (RGFIs) are registered in IGOR (the online Guernsey portal) by June 30, 2020.
There is a potential financial incentive to submitting your CRS reporting to Guernsey by June 30, 2020. In June 2019 the OECD published a new version of the CRS Schema (v2.0) which reflects a number of technical changes. The intention was for v2.0 to be used for Y2020 reporting commencing in 2021.
However, as a result of the COVID-19 reporting extension, Guernsey’s implementation of v2.0 may overlap with Participating Jurisdictions requests for corrected RGFI reporting. It is possible that the RGFI would end up having to submit corrected reporting using v2.0 which would result in higher processing costs (changing over Y2019 data from v1.0 to v2.0).
Please note that Guernsey’s FATCA/CRS team members are currently working remotely. Accordingly, FATCA/CRS questions should be sent via the secure IGOR messaging facility.
Isle of Man
Isle of Man announced it has extended both the FATCA and CRS reporting deadlines to September 30, 2020. However, Isle of Man made clear that filings submitted after September 30, 2020 may be subject to enforcement action.
As with Guernsey (and most Participating CRS Jurisdictions), Isle of Man will be implementing v2.0 CRS schema. If any Isle of Man Financial Institution must file a corrected CRS report (or additional data) after December 1, 2020, the FI must use the v2.0 schema.
In line with the global move toward COVID-19 extensions of time, Bermuda extended its CRS reporting deadline to August 31, 2020. However, all new CRS registrations must be completed by July 31, 2020.
Bermuda warned that strict enforcement measures will apply for any filings submitted after the extended deadlines.