• Marco Zawar MBA/LLM (Tax)

The Inland Revenue Department of Saint Lucia issued updates on its CRS guidelines.

The Inland Revenue Department of Saint Lucia (“IRD”) released Version 4.0 of its “Automatic Exchange Of Financial Account Information Guidelines”.

Version 4.0 makes updates and clarification available to the following areas:

CRS reporting due date (Section 4.0)

The reporting due date under the Common Reporting Standard (“#CRS”) for the reporting year 2019 is extended until October 15, 2020 (initial July 31, 2020).

The updated reporting due date for CRS is now one month later as the #FATCA reporting due date, which is currently September 15, 2020.

Reporting Responsibility (Section 5.0)

IRD highlight that Financial Institutions, which not meet the criteria stipulated in Section VIII B allowing them to be treated as Non-Reporting Financial Institution, are required to file a CRS return by not later than October 15, 2020.

Reporting obligations (Section 7.1. and 7.1.2)

IRD provides clarification about payments that needs to be reported in accordance to the account type.

The manual stipulates additionally, that for reportable accounts not having a Tax Identification Number ("#TIN") or Date of Birth (“#DoB”) the relevant fields in the report shall be blank.

Treatment of low value accounts (Section

The policy provides clarification to the extent, that an account holder having indicia to a reportable jurisdictions shall not to be treated as resident in a reportable jurisdiction for such cases, where the FI has reviewed and maintained a self-certification that does not include the reportable jurisdiction and has documentary evidence establishing the Account holders non-reportable status.

The guidelines spells out in addition, that low value account having a

  • current effective power of attorney; or

  • signatory authority

granted to a reportable jurisdiction, shall not be treated as reportable account in such cases, where “the FI has reviewed or maintained records of a self-certification that does not include the reportable jurisdiction or; documentary evidence establishing the Account holder(s) non reportable status.”

Review of pre-existing entity accounts not exceed USD 250’000 as of December 31, 2016 (Section

The manual stated, that the review of all entity accounts with an aggregate value or balance that does not exceed USD 250,000 on December 31, 2016, but exceeds the threshold in a subsequent calendar year must be completed within the calendar year, following the year it exceeded the said value.

Undocumented Accounts (Section 8.3.7)

The guidelines clearly stated, that financial accounts having only a “hold mail” or “in-care of” indicia and for which the financial institution is unable to receive a self-certification or any other documentary evidence shall be classified as undocumented account.

This is the only instance where this classification is suitable.

Filling requirements (Section 9.1)

The guidelines requires for each reportable jurisdiction a separate XML file.

About the Author

Marco is a Banker, MBA (finance and accounting) and LLM (international business and tax law) with 30+ years experiences as internal auditor, business consultant, project manager and in-house legal counsel gained in the post-trade, operations, investment and tax compliance environment of leading Private Banking Institutes, Wealth Management Organisations and Central Securities Depository and Clearing houses located in Europe and the APAC Region.

Marco is focused on advisory services and project management in the field of


  • U.S Qualified intermediary regime (QI);

  • Withholding Tax on Capital gains and Investment Income

  • Securities transaction tax (stamp tax); and

  • Austrian, German, Hong Kong, Swiss and U.S. International Tax Law

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