Registration procedure for accountable financial institutions for purposes of the Common Reporting Standard (CRS) entered into force
Order of the Ministry of Finance № 468 as of 30.08.2023 "On approval of Registration procedure and de-registration of financial agents that are accountable financial institutions for the multilateral agreement of competent authorities on the automatic information exchange on financial accounts, common reporting standard and due verification of information on financial accounts" entered into force on 10.10.2023 (with changes made by the Order of the Ministry of Finance № 505 as of 20.09.2023) (hereinafter – Registration procedure).
All financial institutions that are accountable financial institutions for purposes of the CRS Multilateral agreement and Common Reporting Standard (CRS) are subject to registration in the State Tax Service of Ukraine.
Registration procedure establishes:
− procedures for registering accountable financial institutions, deregistering them and making changes to information about accountable financial institutions;
− forms of relevant applications and procedure for filling them out;
− registration peculiarities of joint investment institutes and other organizations for which reporting on accountable accounts is submitted by other persons.
Deadlines for submitting application for registration
Organizations that had status of accountable financial institutions as of June 30, 2023 are required to register in the State Tax Service by December 31, 2023.
If organization did not have status of accountable financial institutions as of June 30, 2023 or was created (registered) starting from July 1, 2023 or later, it’s representative submits registration application to the State Tax Service as accountable financial institution within 60 calendar days after it establishes status of accountable financial institution. Reminder! Date of establishing status of accountable financial institution, from which deadline for submitting registration application of accountable financial institution to the State Tax Service is calculated, is determined in Section XI of Procedure for applying the Common Reporting Standard (CRS), approved by Order of the Ministry of Finance № 282 as of 26.05.2023.
How to submit application?
Registration of accountable financial institution is carried out by submitting application in the electronic form through the taxpayer's Electronic cabinet or other electronic communication means.
Accountable financial institutions that will report on accountable accounts solely on their own (for example banks, insurers, non-state pension funds, credit unions, etc.) are registered once.
If accountable financial institution is a collective investment institution, then the asset management company that manages assets of the respective collective investment institution reports for such accountable financial institution. Asset management company is registered as accountable financial institution for itself and additionally for each collective investment institution.
List of accountable financial institutions
Information on all registered accountable financial institutions is entered into the List of accountable financial institutions maintained by the State Tax Service. Registration details of accountable financial institutions will be made public on web portal of the State Tax Service. Accountable financial institutions that maintain financial accounts will be able to rely on information from the List of accountable financial institutions to determine status of the account holder during application of due diligence measures. Reminder! If the account holder is another accountable financial institution, then such account may not be accountable and therefore not subject to proper comprehensive check and reporting.
Clarification regarding the CRS
In order to ensure proper information and clarification campaign on implementation of the Common Reporting Standard (CRS), the Ministry of Finance together with the State Tax Service provided clarification on practical issues of interpretation of certain terms of the Common Reporting Standard (CRS), including interpretation of the term "Financial Institution" (https://tax.gov.ua/data/material/000/579/695725/InfoList5_2023.pdf).
Commentary text to the Common Reporting Standard (CRS) in Ukrainian and English, as well as other clarifications, is posted on the official website of the Ministry of Finance and web portal of the State Tax Service.
Implementation of the international standard of automatic information exchange on financial accounts into Ukrainian legislation and practice is carried out with support of the European Union Finance Management Support Programme for Ukraine (EU4PFM).