Guernsey recently published Bulletin 2017/3, detailing how Trustee Documented Trusts (“TDT”) must report under the Common Reporting Standard (“CRS”). This bulletin provides guidance on the format for electronic reporting through the Information Gateway Online Reporter (IGOR), the Guernsey electronic reporting portal.
While trusts would ordinarily be considered Reporting Financial Institutions (RFIs) under Schedule 2 of the current CRS Regulations, a TDT may be considered a Non-Reporting Financial Institution as long as two basic criteria are met:
- The trustee of the trust is itself a Reporting Financial Institution; and
- In that capacity the trustee completes all of the CRS reporting requirements, as detailed in Section I of Schedule 2 of the Regulations.
The Bulletin goes on to detail what steps the trustee and the TDT must take to register with IGOR and report electronically through the portal.
It is important to note that the treatment of TDTs under CRS differs from the treatment under FATCA, as detailed previously in Bulletin 2016/4.
To review Bulletin 2017/3 in full, please click here to visit the Guernsey website.
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