Common Reporting Standard

Existing personal customers may also be asked to provide CRS related information in the following circumstances:

• If there is a change of circumstance on a customer’s account(s) which may indicate a change in their status for CRS reporting purposes (e.g. a change of address to or from an address in a CRS reportable jurisdiction).
• If an individual’s account information contains any of the following criteria which may indicate that the individual could be considered tax resident in another country, Bank of Ireland UK may need to request further information or documentation to determine if the customer is reportable under CRS.
  • identification of the individual as a resident of a CRS reportable jurisdiction;
  • current (mailing, residence, post office box or ‘care of’) address in a CRS reportable jurisdiction;
  • one or more telephone numbers in a CRS reportable jurisdiction and no telephone number in the country of the reporting Financial Institution (e.g. a customer who has provided a Spanish telephone number for an account held with Bank of Ireland UK, but no UK telephone number);
  • standing instructions (other than with respect to a depository account) to transfer funds to an account maintained in a CRS reportable jurisdiction;
  • current effective power of attorney or signatory authority granted to a person with an address in a CRS reportable jurisdiction; and
  • ‘hold mail’ instruction or ‘in care of’ address in a CRS reportable jurisdiction, which is the sole address for the account holder.

Having one of these criteria does not mean that a customer is CRS reportable, only that the customer needs closer scrutiny so Bank of Ireland UK may request additional information.

If you wish to open a new bank account with Bank of Ireland UK, or if you are an existing customer and we hold information which may indicate that you could be considered tax resident in another country, we will ask you to certify a number of details about yourself. This process is called “self-certification” and we are required to collect this information under the CRS.

The rules regarding what makes a person resident somewhere for tax purposes differ according to the various countries/territories. It is not a question of where you pay tax; for example, the number of days spent in the country can be a significant factor in determining tax residence in some countries (such as the Republic of Ireland).

You can be considered tax resident in one country/territory and pay tax in another. For example, you may be tax resident in the Republic of Ireland but pay tax in the UK and vice versa.

If you have any further queries regarding how to determine your tax residency, please:

• Visit the page on the OECD Automatic Exchange of Information portal which contains information published by various countries/territories regarding their tax residence rules; or
• Consult a professional tax advisor.

Please note that Bank of Ireland UK cannot provide tax advice. The tax residence rules depend on each customer’s unique circumstances.

Please note that being treated as CRS reportable due to foreign tax residence should not otherwise affect your day-to-day banking service provided by Bank of Ireland UK.

Once Bank of Ireland UK has sufficient information/reason to believe that a personal customer is not resident for tax purposes in a country or territory other than the UK, no further action and no reporting is required (unless such a customer’s circumstances change over time, in which case the customer would need to provide Bank of Ireland UK with updated information so that the Bank could amend its records).

The joint account holder who is not tax resident in a CRS reportable jurisdiction does not have their personal details (such as name and address) included in CRS reporting. However, the total account balance held by both parties to the joint account must be included as well as the total of any amounts paid or credited to the account during the reporting period (such as interest, dividends etc. – see FAQ ‘What information will Bank of Ireland UK report to HMRC?’ below, for details of the amounts to be reported depending on the account type). This means that the account balance and amounts paid or credited to the account are not split among the joint account holders for CRS reporting purposes.

If you have previously provided Bank of Ireland UK with your CRS information, you are required to notify the Bank if there is any subsequent change to that information.

If you are an existing customer, and have never previously been asked to provide CRS information, we may contact you to obtain additional information or documentation in order to confirm your CRS status as we are required to review our existing customer base to identify customers who could potentially be CRS reportable. This could also occur where your account information is subjected to any changes which would give the Bank reason to believe that you may be resident, or no longer resident, for tax purposes in a CRS reportable jurisdiction (for example, a customer changing their address to or from a foreign address).

• The account holder’s name, address, date of birth and in some circumstances place of birth;
• Country(ies) / Territory(ies) of tax residence, and tax identification number(s) (‘TINs’)
• The account number and account balance or value at the end of the reporting period;
• The closure of the account (if it has been closed during the reporting period);
• The type of account (e.g. depository account)
• Gross amounts paid or credited to the account (e.g. interest, dividends, redemption payments – see below)
  • With respect to depository accounts, the total gross amount of interest;
  • With respect to custodial accounts, the total gross amount of interest, dividends, other income and proceeds from the sale or redemption of financial assets; and
  • With respect to other accounts, the total gross amount paid or credited to the account including the aggregate amount of any redemption payments.
• Whether a valid self-certification is held
• Whether the account is a joint account (and, if so, the number of joint account holders)
• Whether the account is new (opened on/after 1^st January 2016) or pre-existing (opened before 1^st January 2016).

The reporting to HMRC will take the form of an annual CRS return.

Existing non-personal/entity customers may also be asked to provide CRS related information. If a customer’s account information contains certain criteria, Bank of Ireland UK may need to request further information or documentation to determine if the customer is reportable under CRS. For non-personal/entity customers the criteria usually include:

• place of incorporation or residence in a CRS reportable jurisdiction;
• current (mailing, residence, post office box or ‘care of’) address in a CRS reportable jurisdiction; or
• indication that the controlling persons (only in relation to certain non-personal/entity customers) may be tax resident in a CRS reportable jurisdiction.

Having these criteria does not mean that the entity is CRS reportable, only that the customer needs closer scrutiny so Bank of Ireland UK may request additional information.

See the ‘important documents‘ section below for details of the forms accepted by Bank of Ireland UK for CRS purposes.

If you have previously provided Bank of Ireland UK with the CRS information for your entity, you are required to notify the Bank if there is any subsequent change to that information.

If you are an existing non-personal/entity customer, and have never previously been asked to provide CRS information, we may contact you to obtain additional information or documentation in order to confirm your entity’s CRS status as we are required to review our existing customer base to identify customers who could potentially be CRS reportable. This could also occur where your entity’s account information is subjected to any changes which would give the Bank reason to believe that your entity may be CRS reportable, or no longer CRS reportable (for example, an entity changing its address to or from a foreign address).

• customers who are resident for tax purposes in a CRS reportable jurisdiction; or
• certain entities (Passive NFEs or Investment Entities which are located in a Non-CRS participating jurisdiction) with controlling persons that are resident for tax purposes in a CRS reportable jurisdiction.

Please refer to the glossary for the definitions of Passive NFE, Investment Entity and controlling persons.

In addition, Bank of Ireland UK may also need to report information about customers who do not provide the required documentation to us. For example, where Bank of Ireland UK identifies any of the criteria outlined at FAQ ‘What non-personal/entity customers are impacted by CRS?’ above, but the customer does not provide the requested self-certification form to confirm their information, Bank of Ireland UK may be required to include them in CRS reporting on the basis of the identified criteria.

Where a non-personal/entity customer is found to be CRS reportable, financial institutions must generally report the following information to the local tax authority:

• The name and address of your Entity/Organisation;
• Country(ies)/territory(ies) of tax residence and tax identification number(s) (TINs);
• The type of account (e.g. depository account) and account number;
• The account balance or value at the end of the reporting period or date of closure (if the account was closed during the reporting period) ;
• Gross amounts paid or credited to the account (e.g. interest, dividends, redemption payments);
• Whether a valid self-certification is held;
• Whether the account is new (opened on/after 1^st January 2016) or pre-existing (opened before 1^st January 2016);
• In certain circumstances, the name, address, country(ies)/territory(ies) of tax residence, tax identification number(s) (TINs), date of birth, place of birth and role(s) of the controlling persons of the Entity/Organisation may also be shared.

The reporting to HMRC will take the form of an annual CRS return.

Please refer to the glossary for the definitions of Passive NFE, Investment Entity and controlling persons.

Personal customers – FATCA and CRS Self-Certification form

Business customers – FATCA and CRS Self-Certification form

When making requests from affected customers, Bank of Ireland UK will provide full details of the information and documentation needed for CRS purposes.

View further details on FATCA.

It is important that you respond to all requests for information in respect of both FATCA and CRS even if you believe you have already supplied it.

Depending on the answers provided to the CRS questions on the self-certification form, a customer may be considered CRS reportable or not. If not, the self-certification form is simply stored as evidence of their non-reportable status. If deemed reportable, the self-certification form is again stored to record their status, but such customers’ financial account information may also need to be reported to HMRC (who may share it with the tax authorities in other jurisdictions).

We will only disclose your information to HMRC if we are legally required to do so. Tax authorities who receive the information must also ensure that your data remains confidential.

Bank of Ireland UK may also need to report details of existing customers who do not provide the required CRS information to us on the basis of the information and documentation we hold in our possession. We therefore ask our customers to respond to any requests to properly document themselves for CRS purposes so that we can apply the correct CRS status upon reporting. This is also an opportunity for our customers to update their personal data.

If you have any further queries regarding how to identify your TIN, please:

• visit the page on the OECD Automatic Exchange of Information website which contains TIN information published by various countries/territories; or
• consult the local tax authority in your jurisdiction of tax residence.

• Visit the OECD Automatic Exchange of Information Portal which contains more information on CRS.
• Visit the Gov.UK website; and/or
• Consult a professional tax advisor.

Please note that Bank of Ireland UK cannot provide tax advice.