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CRS - Submitting notification of missing self-disclosure

You do not have a self-disclosure from your new customer for the Common Reporting Standard? After the deadline has passed, you as a financial institution subject to the reporting obligation are obliged to report the absence of the self-disclosure.

The Common Reporting Standard (CRS) is a procedure for the international exchange of tax information with the aim of preventing tax evasion. More than 100 countries participate in the procedure, including the Federal Republic of Germany. The Federal Central Tax Office (BZSt) oversees the procedure in Germany.

The CRS obliges financial institutions in Germany, such as banks or insurance companies, to transmit information about their customers' reportable financial accounts to the Federal Central Tax Office (BZSt). If accounts have a reportable connection to foreign countries, the BZSt exchanges this data with CRS partner countries and in return receives information from the partner countries on accounts abroad whose holders are resident in Germany.

The CRS also regulates due diligence requirements that financial institutions must meet in order to identify accounts subject to reporting requirements. These include obtaining self-disclosures from new customers (natural persons and legal entities) when opening an account. The self-disclosure contains information on the tax residency of the holder.

The self-disclosure must be obtained from the responsible financial institution no later than 90 days after the account is opened and transmitted to the BZSt. If it is not available by then, the lack of the self-disclosure must be reported to the BZSt. The report can be submitted online or by mail.

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