Guidance on FATCA/Common Reporting Standard

The Common Reporting Standard (CRS) became live at the start of 2016 in a number of countries including the UK and Ireland. Its goal is to help identify individuals who may have assets and income in other jurisdictions. To help put this into context, CRS is commonly seen as an extension of the  Foreign Account Tax Compliance Act (“FATCA”) which was enacted in the US on 18 March 2010. This regime has  been adopted in a number of other jurisdictions, including the UK, where it is now local law.

Standard Life is therefore responsible for identifying where customers are tax resident, and where required, to report their details to HMRC or the Irish Revenue.  While these rules initially applied to US person overseas, over 90 additional countries have now signed up for similar arrangements with more expected to join in future.

We’ve made a number of changes to both our paper and online new business applications, together with some of our servicing processes, in order to capture the necessary information we need to comply with the new requirements.

This affects most products except pensions, ISAs and mortgages. While pensions and ISAs themselves are out of scope, additional questions must be answered for Wrap SIPP and Wrap/FundZone ISAs because their associated cash accounts are in scope. 

Here is a list of the main products affected:

 Individual 
 products
 Wrap products FundZone
 products
 Bonds
 Purchased Life 
 Annuity
 Wrap SIPP  FundZone 
 Supermarket
 Cash
 Peppercorn Investment 
 Bond
 Homeplan  Wrap ISA  FundZone 
 Investment
 Funds
 Tailored Investment 
 Bond
 Versatile
 Investment 
 Plan
 Wrap Cash  FundZone 
 ISA
 Capital Investment Bond
 Variable
 Protection Plan
 Wrap Onshore
 Bond
   Distribution Bond
   Wrap Personal
 Portfolio
   With Profits Bond
   Wrap International
 Portfolio Bond
   Onshore Bond
       International Bond

 
Why have you removed ‘none of the above’ as an option?

Originally the ‘none of the above’ option was included for use when a client fell into one of certain specialist categories that we expected very few of our customers would need to use.

These categories include international organisations, government departments and bodies covered by specific US tax concepts. However, we have identified that it was being used where someone wasn’t sure of the correct classification e.g. a kind of not sure.

Experience has proven that all business received since these changes were introduced have fallen into one of the common categories. Please see the glossary on the adviser guide if you’re not sure what these common categories are.  If after reviewing the guide you still believe your business doesn’t fit with the categories on offer then please speak to your account manager. This is a global requirement and more information can be found on the gov.uk site

How is a trust viewed under FATCA/CRS?

In most cases, a trust set up to hold a Standard Life bond will not need to consider or comply with any special obligations. There are however exceptions where a trust is defined as a financial institution in its own right, for instance where it has certain professional trustees, or where the trust or its assets may be directly professionally managed. See our adviser guide for more details.

Guide to Advisers

Our adviser guide to FATCA/CRS includes further information on the points covered above as well as:

  • How we are complying
  • Standard Life entities and their respective GIINs
  • A glossary of terms and Q&A