QI has become business as usual, but much of the technical details have evolved over time and there are periodic certification and ongoing reporting and withholding obligations.
FATCA rules were published in 2010 and went live in 2014. However, interpretation of the rules, evolution of the regulations, local enforcement, annual reporting and ongoing certification requirements continue to be a challenge for financial institutions.
Certain obligations under 871(m) are already live with additional requirements being phased-in, and thus financial institutions must continue to prepare for implementation.
AEOI/CRS became effective in Switzerland in 2017, but many jurisdictions have different effective dates. Financial institutions with various booking centres may have a difficult time keeping up with the varying dates and local rules for implementing AEOI/CRS. Further, the requests following the exchange of information between jurisdictions are expected to result in additional effort.
We understand that additional clarifications are needed in order to implement the DAC6 rules; however, there are certain steps that businesses should be planning for now.
While Deloitte offers the standard presentations, workshops, and technical advisory on the Tax Transparency regimes, we also provide tailored services, products, and presentations in order to fulfill all of our clients’ needs. Deloitte can assist from the implementation phase to business as usual, including external reviews and assisting with remediation efforts.
There are certain steps that businesses should begin planning for now and Deloitte can help.
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