Financial Services Ireland


FATCA and CRS compliance notices

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Irish Revenue has started issuing several types of FATCA and CRS compliance notices to Financial Institutions (FIs).  These are not audits nor non-audit interventions; they are part of a new process whereby Revenue is gathering information from the various industries to create a robust enforcement program bespoke to each industry sector. This process will most likely result in audits of several different natures.

This information gathering exercise is comprised of two parts and being run from different branches of the tax authority:

  • Reporting – The “non-filer program” is focused on reporting absences/offences, i.e. FIs that are registered and/or reported under FATCA but did not submit a CRS return; and/or have a FATCA GIIN and did not file a FATCA report.
  • Operational compliance – Revenue has kicked off a campaign for FATCA and CRS Quality Assurance (‘QA’) checks.  There is no prescribed method for the QA checks, therefore each Financial Institution may receive a different type of request from Revenue.  Interviews, document review, and sample checks are usually included.

As one of the leading service providers in this area, EY has focused on cost-effective solutions that will match the fast-moving operational change we are seeing in the financial sector.  The key is to use technology to identify anomalies and start the gap identification and remediation process now. Many entities are maintaining data across several systems and/or countries, they are taking the risk of manually consolidating information, which can lead to inaccuracies. At EY we build trust by delivering precision through robotics and AI which has been developed through extensive industry knowledge and input from subject matter experts.  We also work closely with global tax authorities to keep on top of their expectations, data quality, and enforcement plans.

It is important to evolve toward a sustainable AEoI compliance program and maintain a clear and accurate view of compliance status across the organisation – without proper internal controls backed by the right technologies, this is an impossible task.  We encourage financial institutions to get in touch – let’s talk through your process and find out how you can achieve better quality and automate your reporting process.

Amanda Murphy

FS Partner, Business Tax Advisory
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