When can you omit an Account Report under CRS
The CRS User Guide expects that Account Reports always have to be submitted. However, in minuscule sub clauses and allusions reminiscent of soothsayers, the CRS User Guide allows a financial institution to send information but not mention any account balances. Under which circumstances should it be allowed that the core information of the CRS, the account report, be omitted ?
On the one hand the User Guide suggests that banks, only for statistical purposes, Submit information showing that there is nothing to report. This information is not forwarded to other countries, but is meant as a check list for the domestic tax authorities that this financial institution fulfilled its reporting duties. If there is nothing to report, there is nothing to report and the account information need not be included in the message.
A similar situation arises when the financial institution intends to delete a whole message containing many account reports. This operation, i.e. deletion of a message, seems to be necessary since some financial institutions have been unable to properly track what has been transmitted and were looking for a fresh start. Instead of compelling these frest start institutions to delete every account individually, the CRS drafters in wise forebodings have allowed financial institutions to delete whole messages by populating the field CorrMessageRefID. Admittedly this is clumsy on several levels (semantically we enter the realm were a deletion is deemed to be a correction), but practically very much required. Under these circumstances as well, a bank might be allowed to omit Account Reports.
When a bank tries to correct information relating to itself, i.e. it changes its name, corrects its address, the bank account information is not affected. The CRS User Guide when providing an example of such an operation (see page 258 of the Purple Book), mentions en passant that an account report needed not to be included. This type of correction of course leads to a flurry of activity at the competent authority which has to convert this deletion of message into a deletion of accounts (see previous article), but this is a minor cost of such a useful instrument.
There you have it: Three instances when a financial institution may omit an account report nothing to report message, deletion of message, and correction of information pertaining to a reporting financial institution.
When can you omit an Account Report under CRS was originally published on Common Reporting Standard