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CRS and FATCA HSBC

CRS and FATCA HSBC

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Old Jun 22nd 2022, 8:23 am
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Default CRS and FATCA HSBC

Hi All,

Hope this finds all expats in good health.
I am a British Citizen, relocated from United Kingdom to Iraq on a rotational role. I go to India during off rotation.
Recently I received an email from HSBC asking to fill CRS & FATCA form, indicating this is an HMRC requirement.
I get paid in UK for Iraq income. I still have rental income in UK?
Anyone aware of this & if it has any tax issues?
Any tips / guidance will be appreciated
Mittdee
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Old Jun 22nd 2022, 2:06 pm
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Default Re: CRS and FATCA HSBC

The CRS form is a G20-sponsored standard tax reporting form for many countries, FATCA is the tax form for the US, so if you have no connecton to the US the FATCA form may have been sent to you by accident.

Last edited by Pulaski; Jun 22nd 2022 at 2:24 pm.
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Old Jun 22nd 2022, 4:40 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Pulaski
The CRS form is a G20-sponsored standard tax reporting form for many countries, FATCA is the tax form for the US, so if you have no connecton to the US the FATCA form may have been sent to you by accident.
Thanks for the reply. Appreciated.
Does it have tax implications or cause any issues?
regards
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Old Jun 22nd 2022, 5:10 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Mittdee
Thanks for the reply. Appreciated.
Does it have tax implications or cause any issues? ...
Neither forms should have tax implications or cause issues ..... so long as you have paid all your taxes in the jurisdictions where you are liable for taxes! ..... That is the background and purpose to the forms, to collect personal financial data and share it, persuant to legislated requirements, with the taxing authority(ies) to which you are connected. So if you pay all your taxes, keep your financial affairs in order, and haven't salted away a nest egg in an off-shore banking tax haven, then you have nothing to worry about.
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Old Jun 22nd 2022, 6:08 pm
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Default Re: CRS and FATCA HSBC

The CRS form simply means that HSBC will report your earnings to HMRC (which they have to do - CRS is just showing where to report you, UK, UAE, France etc.). If you are compliant with the tax rules and/ or report them anyway then there is no implication. If you are breaking tax rules, then the CRS reporting is designed to help Mr Taxman catch you.

Only you know what side of that coin you sit on.
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Old Jul 5th 2022, 1:09 pm
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Default Re: CRS and FATCA HSBC

Thanks all for your responses. Much appreciated.
I had started to fill the CRS/FATCA form, however it asks my country of residence. Actually I work in Iraq with 28 days in Iraq with 28 days holiday, outside Iraq. I am currently going to India in off rotation. I am not sure if I should mention India address (parents address) where I live.
In UK, my parents address is the correspondence address. I wonder if UK bank will consider my India address, for tax residence. I have no income in India. I am getting paid in UK for Iraq income. I have rental income in UK.
Also the form asked for TIN Number (Tax Identification Number) for each country I am tax resident.
Any help / experience will be much appreciated.
MD
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Old Jul 5th 2022, 1:53 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Mittdee
Thanks all for your responses. Much appreciated.
I had started to fill the CRS/FATCA form, however it asks my country of residence. Actually I work in Iraq with 28 days in Iraq with 28 days holiday, outside Iraq. I am currently going to India in off rotation. I am not sure if I should mention India address (parents address) where I live.
In UK, my parents address is the correspondence address. I wonder if UK bank will consider my India address, for tax residence. I have no income in India. I am getting paid in UK for Iraq income. I have rental income in UK.
Also the form asked for TIN Number (Tax Identification Number) for each country I am tax resident.
Any help / experience will be much appreciated.
MD
But where are you tax resident? ..... It would be unusual, and likely severely disadvantageous (expensive), to be tax resident in more than one country.

On the limited information you provided, and assuming you left the UK for work purposes and have been out of the UK long enough to sever that link (having rental income is not relevant for establishing "tax residence") it sounds to me like you're tax resident in Iraq, where you work, and live while you're working. ..... Though it makes me wonder if the form is either [1] asking for all countries where you pay tax, which is different from being "tax resident" OR [2] if you're confusing "paying tax (on rental income)" with being "tax resident"?
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Old Jul 5th 2022, 2:11 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Pulaski
But where are you tax resident? ..... It would be unusual, and likely severely disadvantageous (expensive), to be tax resident in more than one country.

On the limited information you provided, and assuming you left the UK for work purposes and have been out of the UK long enough to sever that link (having rental income is not relevant for establishing "tax residence") it sounds to me like you're tax resident in Iraq, where you work, and live while you're working. ..... Though it makes me wonder if the form is either [1] asking for all countries where you pay tax, which is different from being "tax resident" OR [2] if you're confusing "paying tax (on rental income)" with being "tax resident"?
Thanks a lot Pulaski.
You are right to say, I left UK in Dec 2020 & was working from remote (India) for my UK employer, via my own Limited Company until Dec 2021. I joined Iraq role in Dec 2021 on rotation basis. So for UK, I am not a tax resident, as I only have rental income. The form asks my living address & also all locations I am tax resident, which will be Iraq, as there is 15% deduction on income received. Form asks for TIN, which I am not very clear about. I think, I am not tax resident in UK. So I should indicate only Iraq as resident for tax purposes?
Thanks
MD
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Old Jul 5th 2022, 2:29 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Mittdee
Thanks a lot Pulaski.
You are right to say, I left UK in Dec 2020 & was working from remote (India) for my UK employer, via my own Limited Company until Dec 2021. I joined Iraq role in Dec 2021 on rotation basis. So for UK, I am not a tax resident, as I only have rental income. The form asks my living address & also all locations I am tax resident, which will be Iraq, as there is 15% deduction on income received. Form asks for TIN, which I am not very clear about. I think, I am not tax resident in UK. So I should indicate only Iraq as resident for tax purposes?
Thanks
MD
Based on the limited information you have provided, with the additional clarifications, I think it is likely that you are indeed, only tax resident in Iraq. Providing additional information is IMO only likely to cause confusion, and as a former BE member used to advise, as best I remember, regarding forms - answer the questions as plainly written, do not try to alter the questions to fit your circumstances or to answer what you think the question should have been."

Regarding "TIN", that is specific to the US as a "Taxpayer Identification Number" (simliar to a US SSN - Social Security Number) for taxpayers in the US who are not eligible for an SSN. I cannot confirm that "TIN" might not have a wider or different usage outside the US.
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Old Jul 5th 2022, 4:16 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Pulaski
Based on the limited information you have provided, with the additional clarifications, I think it is likely that you are indeed, only tax resident in Iraq. Providing additional information is IMO only likely to cause confusion, and as a former BE member used to advise, as best I remember, regarding forms - answer the questions as plainly written, do not try to alter the questions to fit your circumstances or to answer what you think the question should have been."

Regarding "TIN", that is specific to the US as a "Taxpayer Identification Number" (simliar to a US SSN - Social Security Number) for taxpayers in the US who are not eligible for an SSN. I cannot confirm that "TIN" might not have a wider or different usage outside the US.
Thanks again dear Pulaski.
I am advised by my accountant in UK, that the Unique Tax Payer Reference (UTR), is treated as TIN.
For other advice, seems you are right & I tend to agree with it. I'll follow the same.
Thanks
MD
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Old Jul 5th 2022, 4:32 pm
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Default Re: CRS and FATCA HSBC

Originally Posted by Mittdee
Thanks again dear Pulaski.
I am advised by my accountant in UK, that the Unique Tax Payer Reference (UTR), is treated as TIN.
For other advice, seems you are right & I tend to agree with it. I'll follow the same.
Thanks
MD
UR welcome.
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