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TransferWise and CRS

1nomad

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Apr 28, 2018
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Will you report my transfers to the tax authorities?

TransferWise Limited is a UK company authorised by the Financial Conduct Authority as an Electronic Money Institution. We are still evaluating the impact of the Common Reporting Standards, including FATCA, to our business and how we will adopt the new requirements. At this time we are not reporting this information to HMRC or any other tax authority.
 
You can see exactly what is expected to be reported below to HMRC if they decide to go ahead. Note that closure won't help if they decide to start reporting tomorrow. UK FI's will report all money sent and received during a reportable period...lol.

"When an account is closed the Reporting Financial Institution [see IEIM402100] must report the fact of the closure but is not required to report the balance or value of the account at closure. Any amounts paid or credited to the account in the reporting period up to the date of closure remain reportable [see IEIM402220 to IEIM402260]."

How to report Automatic Exchange of Information
 
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.
 
Belgium is still Europe and part of the EU so the CRS policies as explained above remain untouched. They should have moved outside of the EU to avoid the reporting of accounts.
 
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Belgium is still Europe and part of the EU so the CRS policies as explained above remain untouched. They should have moved outside of the EU to avoid the reporting of accounts.

This is our point of view as account holders. Now think what would their base of clients be in case EU prevents them from properly operating in EU, with proper rights as they do now.
 

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