Financial institutions from more than 50 early adopter jurisdictions began AEOI/CRS Reporting in the first quarter of 2017, and in a few short months (January 2018) 51 "Wave 2 countries" including Switzerland, Singapore, Panama, Monaco, Japan, Hong Kong, Canada, Bahamas, Austria, Andorra will submit their 2017 reports.
Given that incorrect and/or late reporting may lead to penalties, firms are on edge as they tackle multiple challenges concurrently, including data management, deployment and operating models. These ramifications are compounded further by the sheer complexity of the CRS regulation.
With the last deadline for CRS (and some banks already reported for early adoption jurisdictions), the numerous operational challenges involved in CRS implementation needed to be addressed by compliance and operations specialists alike. If FATCA projects can provide the building blocks of CRS implementation, the scale and scope of the rules became clearer and financial institutions have realized that the increased complexity of CRS compared with FATCA meant there is a lot of work for them to do.
Consequently, the industry is focused not just on making sure it is collecting the necessary information for reporting, but also on ensuring that the appropriate governance procedures are in place to allow it to be accessed easily, and that clients are aware of – and on board with – the requirements.
Patrick Wilson is currently the Head of Tax Advisory at Credit Suisse for APAC, providing technical advice and support to Credit Suisse Client Tax Reporting for Credit Suiise entities in the APAC region. As Patrick previously managed CRS compliance at Coutts Private Bank in the UK Patrick has experienced CRS implementation in a Wave 1 country and is now seeing it from the perspective of a Wave 2 country. Patrick is a Fellow of the Institute of Chartered Accountants, holds a Masters Degree in International Tax Law and is currently researching his PhD addressing the question 'Is the Automatic Exchange of Finacial Information an equitable device to address tax evasion?'
Remi joined BearingPoint in 2011 and is the deputy product manager of the FiTAX reporting solution. He is an expert in regulatory tax reporting regimes such as QI, FATCA, CRS and DAC6. He supported many FiTAX software implementation projects at financial institutions in the U.S., Europe and Asia.
Fabrice is a professional with 20 years’ experience providing software and services in the financial sector. Fabrice is Director at BearingPoint. He joined the company in 2003 and he is currently head of FiTAX BearingPoint’s tax software. He is responsible for the team as well as the software development, delivery and implementation projects of FiTAX modules. FiTAX covers regulatory tax reporting regimes such as QI, FATCA, CRS/AEOI and DAC6/MDR.
Ronald Frey is Chief Product Officer of the RegTech product unit within BearingPoint and responsible for the product strategy and management of the Swiss regulatory reporting product FiRE as well as for the tax reporting products EasyTax and FiTAX. He is an expert in tax authority reporting (QI, FATCA and CRS), in tax reporting for individuals (income, wealth and capital gain) and in implementation of BearingPoint's tax software solutions. Ronald Frey’s focus is to drive international growth for the Swiss RegTech products.
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