The Spanish Tax Administration has published additional answers to Frequently Asked Questions regarding FATCA and CRS reporting. The questions address specific circumstances – under both FATCA and CRS – in which a Financial Institution is obligated to carry out blocking of a financial account for both entities and natural persons:
- A Financial Institution must block an account of an individual when the TIN is not included in a new account declaration. Additionally, the FI must communicate that the TIN is missing to the country or jurisdiction of tax residency that appears in the new account declaration.
- For entity accounts, the mere absence of an active or passive determination does not require the FI to block the account.