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If an entity account holder has controlling persons that are tax resident in multiple jurisdictions, do they need to be reported in separate filings?

  • Updated

Yes. For account holders that are Passive NFEs with controlling persons who are CRS reportable persons, the entity account will need to be submitted separately for each receiving country, with the relevant controlling person information included in each.

For example, if a Passive NFE has reportable controlling persons that are tax resident in Ireland, Spain, and Mexico, they would need to include the relevant controlling person details (along with the account information) in three separate filings, with receiving country values of Ireland, Spain, and Mexico.

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