OECD publishes updated CRS FAQ
The OECD recently published an updated CRS FAQ. Most important is the publication of measures to force financial institutions to obtain self-certifications from all new individual and entity accountholders. Belgian financial institutions should monitor the number of undocumented new accounts and freeze or even close these accounts after 90 days.
Another important modification is the expansion of the ‘excluded accounts’ definition. Financial Account held by or on behalf of a group of owners or by the condominium company (Vereniging van mede-eigenaars/ Association de copropriétaires) for the purpose of paying the expenses of the condominium or housing cooperative may be included in the jurisdiction-specific low-risk list of Excluded Accounts. An adaption of the Belgian legislation and CRS guidance should be envisaged, as these entities are actually classified as ‘active NFE’.
Other FAQ’s give some more clarification with respect to the reporting obligations of liquidating FI’s and the determination of the controlling persons of a Passive NFE. These updates are in line with the Belgian guidance.
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