Is the CRS FI portal registration driving you nuts? Go ahead and try de-registrations

Emelie Mahler
Emelie Mahler
Senior Manager, Head of Regulatory
Is the CRS FI portal registration driving you nuts? Go ahead and try de-registrations

After a demanding CRS reporting period, we slowly enter calmer waters. But lean back in your executive chair and put your feet up? Not so fast. Not only are you required to make sure that the relevant entities are registered and carrying out its reporting obligations. You must also keep check on your FI registrations, and under certain circumstances change or cancel them.

After a demanding CRS reporting period, we slowly enter calmer waters. But lean back in your executive chair and put your feet up? Not so fast. Not only are you required to make sure that the relevant entities are registered and carrying out its reporting obligations. You must also keep check on your FI registrations, and under certain circumstances change or cancel them. 

There are in general three reasons why you want to request a de-registration or a transfer of user rights:

  • De-registration due to liquidation/termination of an entity
  • De-registration due to change in classification of an entity from FI to NFE
  • Transfer of user rights due to the change of reporting service provider

The process of de-registrations or transfer or user rights

The process differs from jurisdiction to jurisdiction, which is confusing enough. In many jurisdictions, you must contact the relevant authority in written via letter or email to request a de-registration or the transfer of user rights. For example, in Switzerland, you must send a request to the Swiss Federal Tax Administration in writing, explaining the rationale behind the de-registration or inform that the user rights are being transferred so that they can delete the FI registration from your profile as soon as the new service provider has activated the user rights on their end via an invitation code that you must provide them with. It is advisable to submit relevant supporting documentation as a basis for the request. This will avoid back-and-forth and speed up the process.

The BVI recently integrated the process of de-registration and transfer of user rights into their reporting portal, where you now must submit such request in a similar manner as you would file a CRS or FATCA return, along with relevant supporting documentation.

While in some jurisdiction, the procedure goes smooth, in others it can take months until the de-registration or transfer or user rights is processed, so patience and perhaps a couple of reminders might be required.

Keep your checklist ready

Does it seem complicated? No worries, we will set out a few key points for you.

  • Do you know how to request a de-registration or transfer or user rights? Consult the Guidance from the relevant authority, if available, or contact them directly to ask what you need to do.
  • Have you fulfilled all your reporting obligations up until de-registration or transfer? This should go without saying, but it is of course important that you have fulfilled all your reporting obligations first.
  • Do you have the relevant documentation at hand, if you will be required to provide it to the authorities? This might mean copies of certificate of liquidation, deed of termination, financial statements or other statutory documentation or agreements, contact details to the new service provider – all depending on the reason for your request. If you are not able to provide such information as required, you can expect the procedure to drag out, or worst-case scenario that your request is being rejected.  

If you follow these steps, you should already be on a good way. If you have questions or need assistance with FI registrations or de-registrations, please however feel free to contact us at crs@kendris.com.