The case
The OECD has published the 2nd of the CRS Implementation Handbook, (“Handbook”) which provides a practical guide to implementing the Common Reporting Standard (“CRS”) to both government officials and financial institutions. However, the Handbook is not part of the CRS. The purpose of the Handbook is to assist government officials in the implementation of the Standard for the Automatic Exchange of Financial Account Information in Tax Matters (“Standard”) and to provide a practical overview of the Standard to both the financial sector and the public at-large.
Source: OECD
The commentary
The Handbook provides an overview of the legislative, technical and operational issues and a more detailed discussion of the key definitions and procedures contained in the Standard Common Reporting Standard. Changes reflected in the 2nd edition of the Handbook provide additional and more up-to-date guidance on certain areas related to the effective implementation of the Standard. This includes revisions to sections pertinent to the legal framework for implementation of the AEOI, data protection, IT and administrative infrastructures as well as compliance measures. More information has been provided in the trust section of the Handbook in relation to the identification of Controlling Persons, e.g. CP of an FI Trust (Note 253). Further, Table 8 “Financial activity to be reported where the trust is a pNFE” has been up-dated (p. 124). The 2nd edition of the Handbook also includes all Frequently-Asked Questions in relation to the CRS that have so far been issued by the OECD. The FAQs are intended as a “living document” and regularly updated.