HMRC has published a reminder that the deadline for submitting Automatic Exchange of Information (AEOI) returns for the year ended 31 December 2016 is 31 May 2017.
As well as reportable accounts for the Financial Accounts Tax Compliance Act (FATCA) and the Crown Dependencies and Overseas Territories (CDOT), this is the first year that returns should include information for the Common Reporting Standard (CRS). Unlike FATCA and CDOT, there is no charity exemption from reporting under the CRS, meaning that charities classed as Financial Institutions will have a responsibility to conduct due diligence and submit a report on any relevant “account holders”.
While HMRC has previously stated its intention to offer a “soft landing” approach to affected charities, it has made clear that returns submitted after the deadline, or the filing of an incorrect return, may result in penalties being charged. As such, Financial Institutions are being advised to check whether they need to register and submit an AEOI return and, if so, make the submission in advance of the 31 May deadline. If a charity is still in any way uncertain as to its status in relation to the CRS, we would encourage them to seek professional advice to make certain of their situation and any reporting requirements.
More information on the CRS on the requirement to register and submit returns can be found here.