FATCA Return Validation
Revenue have implemented stricter FATCA validation rules for FY16 FATCA reporting.
On 22 April 2016, Revenue released a new offline FATCA Return validator on their Revenue Online Service (“ROS”) to help financial institutions validate their FATCA return files in advance of submitting them to Revenue using ROS. Once the file passes the offline validation using this tool, it is ready for submission to Revenue using ROS.
The new validator takes account of the stricter validation rules for FY16 FATCA reporting following feedback received by Revenue from IRS after the first FATCA file exchange between Ireland and the United States in 2015. The purposes of these stricter validation rules is to ensure that the FATCA returns which will be sent by Revenue to the IRS from September 2016 will pass IRS validation rules and comply with US FATCA requirements. Details of common FATCA file errors which arose during Revenue’s return exchange with the IRS in FY15 have been published by Revenue and should be noted by Irish persons preparing FATCA returns for filing for FY16.
While the validation has been enhanced, the process for filing FATCA returns has not changed from 2015. You should ensure that if you are filing FATCA returns in FY16 that you recheck that you have access to the ROS filing facility ahead of the June 30th deadline.