Insights

Common Reporting Standard

Impact on Listed Funds

The Common Reporting Standard (CRS) is now live and has brought with it a number of new regulatory requirements for in-scope Financial Institutions.

Overview

The Common Reporting Standard (CRS) is now live and has brought with it a number of new regulatory requirements for in-scope Financial Institutions. One key change is the absence of a reporting exemption for listed equity and debt. This is contrary to the US FATCA position where the definition of in-scope accounts specifically excluded equity and debt interests in investment entities where those interests were regularly traded on an established securities market.

The removal of this provision means that equity and debt interests in certain entities, such as listed funds and exchange-traded funds (ETFs), may be reportable under CRS if they are held by non-domestic investors. Financial Institutions may therefore have additional compliance obligations including investor due diligence and reporting. There may be some practical difficulties for ETFs to identify the account holders to satisfy the due diligence requirements. Revenue is in process of reviewing the situation and is likely to consult with other jurisdictions on this matter.

If you are not aware of your CRS obligations or would like further information on CRS please contact a member of the Deloitte CRS team.

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