Common Reporting Standard

What is it?

Common Reporting Standard (CRS) is a global standard initiated by the Organisation for Economic Co-operation and Development (OECD) aimed at preventing tax evasion and involves the exchange of certain account information between jurisdictions that have signed up for CRS. More information is available at the OECD Automatic Exchange of Information Portal.

At present 100+ jurisdictions have committed to implementing CRS including Ireland and the UK. This means they have adopted CRS rules with effect from 1 January 2016.

CRS imposes obligations on Financial Institutions including Prudential International Assurance (PIA) to review and collect information to identify an account holder’s country of tax residence and provide certain account information to either the Irish Revenue Commissioners where the account is held with PIA or HMRC where the account is held with PIA UK branch (Prudential Onshore Portfolio business).
 

How is PIA Complying with CRS?

PIA and its PIA UK branch have implemented CRS rules since 1 January 2016. This means that:

1. For any new offshore PIA business where the applicants, including certain controlling persons, are non-Irish tax residents it is mandatory for PIA to collect their overseas country(ies) of tax residence and TIN(s).
    
2. For any new PIA UK branch business where the applicants, including certain controlling persons, are non-UK tax residents, it is mandatory for PIA UK Branch to collect their overseas country(ies) of tax residence and TIN(s).

Where the information above is not provided, the plans cannot issue.

PIA and PIA UK branch will report this information, to the Irish Revenue Commissioners or HMRC, as appropriate, in compliance with CRS regulations.
 

What is a TIN?

A TIN is Tax Identification Number (TIN). It's a unique code given to a person or entity to identify them for tax purposes. In the UK it is the NINO (national insurance number) or UTR (unique tax reference).

If a jurisdiction issues joint TINs or permits joint taxation, a TIN specific to each individual applicant is required i.e. the National Insurance Number or Social Security Number for each individual as opposed to a joint TIN is required. 
 

What does CRS mean for PIA clients who had a Plan in force prior to 1 January 2016?

PIA and PIA UK branch were required to review any plans in force as at 31 December 2015 to determine whether or not they may be reportable for CRS.

As part of this review, PIA wrote to these existing clients, where applicable asking them to complete Tax Residency Self-Certification forms confirming their country(ies) of tax residence(s) and TIN(s). 

Where a response has been received, PIA and PIA UK branch will report, if applicable, the confirmed tax residency information together with any other relevant account information to the relevant tax authority. 

Where a policyholder has not provided a response, a review will have been carried out to determine their tax residency. As a result, PIA and PIA UK branch, may report that tax residence (or multiple tax residencies) to the relevant tax authority along with the other required account information. 
 

When will PIA and PIA UK Branch report to the Irish Revenue Commissioners and HMRC?

For PIA business - CRS returns for the previous calendar year are submitted to the Irish tax authorities by 30 June each year.

For PIA UK Branch business - CRS returns for the previous calendar year are submitted to the UK tax authorities by 31 May each year.

The Irish Revenue Commissioners and HMRC are then required to exchange the required information with the tax authorities of the relevant overseas CRS participating jurisdictions by 30 September each year. 
 

What happens if a client does not provide their tax details to us as requested? 

For new business issued since 1 January 2016, the plan cannot be issued. 

For plans that issued before 1 January 2016, and the client has not returned the Tax Residency Self-Certification form to us we will be required to report to the tax authorities based upon the information we have on our records, which may not be an accurate reflection of the client’s tax residence. It is therefore in the client’s best interest to provide us with the correct information. 

Furthermore as the information we have on our files may point to multiple tax residencies we may be required to report each of these in the absence of confirmation of the correct information from the policyholder.
 

What Information is required?

Individual Owners

For individually owned Plans we require the completion of a Tax Residency Self-Certification form which requires the clients to confirm the following: 

1. Name, 
    
2. Date of birth,
    
3. Residence address,
    
4. Jurisdiction(s) of residence for tax purposes and
    
5. TIN with respect to each Reportable Jurisdiction.

This form must be self-certified. A self-certification is valid only if it is signed (or otherwise positively affirmed) and dated by the policy owner(s). For joint owners, each owner should provide a signature confirming their own details. 
 

Entity Owners

We require the completion of a Tax Residency Self-Certification form confirming their

1. Name,
    
2. Address, 
    
3. Country(ies) of tax residence, 
    
4. TIN(s) of the entity, 
    
5. Entity Type,
    
6. Tax information on Controlling persons*

*Depending on the type of entity, information may be required in respect of its controlling persons. There needs to be a valid authorised signature under all controlling persons to certify that the details provided for each controlling person are correct. In some cases this will require an authorised signatory to sign multiple times under each controlling person.
 

Who should I contact if I have any questions with regard to CRS?

You should contact your Prudential Sales Support team.