Do prepaid cards fall under the CRS?

[Lullaby]

Hi, I would like to know if prepaid cards without IBAN fall under the CRS. I have searched around a lot but found nothing useful. Since most of them do not require TIN, how do they report with CRS? The XML file used for reporting requires the TIN.
Do they use another system?

Thanks.

 

[ikan]

If we talk prepaid card delivered by "Financial Services Companies "under EU regulation. As far I may know they do not report.
If we talk prepaid card delivered by EU bank or some of their subsidiary financial services : they shoudl report more easily.
Anyhow, if needed, tax man can enquiry directly from those entites and collect usefull infos about you and what do you do with prepaid card.
No matter it is IBAN or not. The matter is : card under your name processing funding and spending, regardinf fact you did comply ID verification with the Card supplier.
I'm not expert. Maybe I"m wrong ? some guys here may know a lot more.

 

[Lullaby]

If we talk prepaid card delivered by "Financial Services Companies "under EU regulation. As far I may know they do not report.
If we talk prepaid card delivered by EU bank or some of their subsidiary financial services : they shoudl report more easily.
Anyhow, if needed, tax man can enquiry directly from those entites and collect usefull infos about you and what do you do with prepaid card.
No matter it is IBAN or not. The matter is : card under your name processing funding and spending, regardinf fact you did comply ID verification with the Card supplier.
I'm not expert. Maybe I"m wrong ? some guys here may know a lot more.

Yes, I know, but I'm talking about automated exchange of information and not inquiries from an authority.
To be clear, I am primarily concerned with CRS within EU countries.
I have done further research and as you can see from this document, their preferred way for recognizing a taxpayer is to use the TIN, but not all financial companies are obliged to request it from their client. Therefore other data are also used to identify the taxpayer such as date of birth and address (these are mandatory with any financial company), although less precise and subject to errors between the systems that manage this type of information.

 

[JohnLocke]

For me it looks almost impossible to do any reporting for prepaid cards, unless you mean debit cards. Prepay Cards are still in many countries anonymous to buy at some point.

 

[Lullaby]

For me it looks almost impossible to do any reporting for prepaid cards, unless you mean debit cards. Prepay Cards are still in many countries anonymous to buy at some point.

Is there still any service offering virtual prepaid cards online?

 

[JohnLocke]

Is there still any service offering virtual prepaid cards online?

There are listed a handful in the RESOURCE section of the mentor group, otherwise Google your way to them.

 

[Martin Everson]

Hi, I would like to know if prepaid cards without IBAN fall under the CRS. I have searched around a lot but found nothing useful. Since most of them do not require TIN, how do they report with CRS? The XML file used for reporting requires the TIN.

I covered this in detail in below post:

Credit cards and CRS

Does anyone have definitive answer on whether or not credit card accounts are reported or not under CRS? I was sure they were NOT, but after reading original CRS papers i'm not so sure anymore If they are not, that certainly opens some interesting possibilities, because in many countries (HK...

www.offshorecorptalk.com

Do they use another system?

Yes. See below post where I gave real world example.

Hi there - questions inside

Hello, I'm new here, trying to learn new stuff, and hopefully getting some help from some of the forum experts. Thanks in advance for taking the time to reading this post. I'm an online consultant with tax residence in EU, and income coming from EU and the US. The income coming from EU is sent...

www.offshorecorptalk.com

Since most of them do not require TIN, how do they report with CRS?

A TIN is not mandatory for CRS exchange. CRS exchange will take place even without a TIN.

 

[Lullaby]

A TIN is not mandatory for CRS exchange. CRS exchange will take place even without a TIN.

No, the TIN is mandatory, it can be left empty only when it is not available (where the customer country does not provide it ) as you can see from the XML schema for CRS at this link (for convenience I attach the interested parties below).

How could they manage a data flow without TIN? Using only the customer first name, last name and address? They would generate ambiguous data because I can write my address in 100 different ways.

For example, I just signed up for the Quppy wallet and I was not asked for a TIN or birth date. If they were to send my CRS XML file what would they write? And once received by my tax authority, how could they associate it with myself?

I think there is a big hole in these regulations.

 

[Martin Everson]

No, the TIN is mandatory, it can be left empty only when it is not available (where the customer country does not provide it )

A TIN is NOT mandatory..lol. Think about what you just said . I never heard of something mandatory where it can be left empty .

How could they manage a data flow without TIN?

Your ID/passport number can be enough.

 

[Lullaby]

Your ID/passport number can be enough.

There is no field for this in the xml file.

 

[Martin Everson]

There is no field for this in the xml file.

In some countries the TIN is same as personal ID and can be used in TIN field. Hence they simply put your National ID number in TIN field. For example in a country like Malta, Maltese Nationals use their Identity card number as TIN.

I repeat again a TIN is not mandatory. It is a good to have but is not the only method a home country receiving CRS data will use to identify a tax payer.

 

[ikan]

@ Lullaby : extend your thinking of the overall. Softwares are done to reports CRS. Softwares don't care to report with missing infos, mistakes, by defautl. Once datas are reported in your home country with a wrong end, don't you think your Tax Man can use another usefull software to cross datas for what he needs to make clear, in case he's searching for something precise........?

Lullaby, looks like your concern is same for me.
Please can you explain about : what is your fear with CRS and Pre-Paid Card. What/how/why are you trying to avoid - escape ?

 

[Untangle]

There is a new legislation that came into force in Europe about Prepaid cards. The name escapes me. But was very recent. Few months ago. Anyways all exotic Prepaid cards are banned if not linked to a properly compliant bank.
And limits have gone down in many countries.
In France I think it is 1000 or 1500 euros, after that you need to register with KYC...or change card.
Usually speaking pre paid cards can be used up to 2500 euros a year, then you need to register KYC.
Not that difficult to go around, but with new legislation, it has become harder.

 

[isyet]

Hi, I would like to know if prepaid cards without IBAN fall under the CRS. I have searched around a lot but found nothing useful. Since most of them do not require TIN, how do they report with CRS? The XML file used for reporting requires the TIN.
Do they use another system?

Thanks.

Another way as CRS: Go to your Prepaid Card membership page. Download the page as PDF or CSV. Or take a picture of the page. Or copy all. Save or paste to the Word page on your computer. Then save as PDF. Then send it to the bank as a report. Make sure that the bank's logo is on the page. That's how we solved the problem. But not every bank can accept it.