This is a very gray area and I think each
EMI kinda approaches it differently - some may not understand the directive very well. I checked what three providers say - ePayments approach is in direct contradiction with
Leopay which is in direct contradiction with
Transferwise.
Everyone kinda "self classifies" themselves as something.
It is explained in detail here:
https://www.oecd.org/tax/automatic-...-by-jurisdiction/guidance/Cyprus-Guidance.pdf
IEIM400750 - International Exchange of Information Manual - HMRC internal manual - GOV.UK
https://www.e-ma.org/emaweb/wp-cont...regarding-FATCA-and-CRS-13-September-2016.pdf
The real questions you and they should ask:
- is the company an
Electronic Money Institution?
- where is the company located?
- does the company provide "Financial Account"?
- does the company provide specifically "Depository Account"?
- does the company provide specifically "Custodial Account"?
- is the company considered a "deposit taker"?
- can the company provide a "Financial Account" or "Depository Account" when it is not a "deposit taker"?
- if the account is neither "Depository Account" nor "Custodial Account", does the account classify to report "the total gross amount paid or credited to the Account Holder with respect to the account during the calendar year or other appropriate reporting period"?
It is difficult to find answers to these questions.
Some bureaucrat in Brussels created this reporting law without knowing much about it and now expects the companies to solve it themselves. So each company kinda "solves" it their own way.