Implementation of the Common Reporting Standard (CRS): Requirements for Financial Agents

After the introduction of changes to the tax legislation of Ukraine regarding the implementation of the Common Reporting Standard (CRS), financial agents are required to undertake comprehensive verification measures to identify reportable accounts and submit an annual report on such accounts to the State Fiscal Service by July 1st, starting from July 1st, 2023. This information was provided by the press service of the Ministry of Finance.

The first report on reportable accounts will be required to be submitted in 2024 for the second half of 2023 (the first reporting period). Subsequent reporting periods will correspond to the previous calendar year.

To ensure timely implementation of all preparatory stages necessary for the implementation of the Common Reporting Standard (CRS) in Ukraine, the Ministry of Finance, with the support of the EU Program for Public Finance Management Support in Ukraine, is developing relevant sub-legal regulatory acts.

In particular, a draft procedure for the registration and deregistration of financial agents, who are reportable financial institutions for the purposes of the Multilateral Agreement CRS and the Common Reporting Standard (CRS) (subsection 39-3.3.3 of Article 39-3.3 of the Tax Code), has been developed.

The draft stipulates that all financial institutions that qualify as reportable financial institutions for the purposes of the Multilateral Agreement CRS and the Common Reporting Standard CRS (hereinafter referred to as RFIs) must be registered with the State Fiscal Service. RFIs are required to submit an application for registration within 60 calendar days after obtaining the RFI status.

It is important to note that RFIs, which will submit reports on reportable accounts solely on their own behalf, are registered only once.

If an RFI is an investment institution (unit or corporate investment fund), the asset management company managing the assets of the respective investment institution will submit the reporting for such RFI (subsection 39-3.11 of Article 39-3 of the Tax Code). The registration of an investment institution as an RFI is also carried out based on an application from the asset management company. To do so, the asset management company submits an application for its registration as an RFI and for the registration of all investment institutions of this asset management company that are also RFIs.

In general, if an institution submits reporting only for itself, the financial institution is registered as an RFI using its tax identification number.

If the registration application is submitted by an asset management company for the registration of an investment institution, the registration number of the investment institution as an RFI is formed from the tax identification number of the asset management company and the registration number of the respective investment institution in the Unified State Register of Legal Entities and Individual Entrepreneurs.

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