What is CRS and who is concerned?

What is the Common Reporting Standard (CRS)?

At the request of the G20, the Organisation for Economic Cooperation and Development (OECD) established in 2014 a common standard for the exchange of information in order to combat tax evasion and promote fiscal transparency.

This international standard for the automatic exchange of information (Common Reporting Standard, or CRS) asks signatory states which include Belgium to require their financial institutions (banks, insurance companies, investment funds, brokers, etc.) to do the following:

• identify and gather information relating to the account holders and financial beneficiaries of certain entities who are resident for tax purposes in another jurisdiction than the one in which the financial institution is established;
• communicate this information to their local tax authorities. These authorities send this information to the tax authorities of the jurisdiction in which the taxpayers are resident for tax purposes, which may then tax the income in accordance with the national tax legislation of the beneficiary's jurisdiction of tax residence.

Belgium adopted the CRS by the law of 16 December 2015 which obliges Belgian financial institutions to report from 2017 certain financial information to the FPS Finance which will be transmitted by Belgium to the participating CRS jurisdictions.

Who is concerned by the CRS?

All Keytrade Bank clients (natural persons or entities) who are resident for tax purposes in another CRS jurisdiction than Belgium are concerned by the exchange of information. The exchange also concerns legal entities if they have beneficial owners who are resident for tax purposes in another CRS jurisdiction than Belgium.

Which information is transmitted by Keytrade Bank to the FPS Finance?

For each reportable account, Keytrade Bank must provide the following data to the FPS Finance:

• In the case of an individual who is an account holder:
  • the name, address, jurisdiction(s) of residence, tax identification number(s) (TIN(s)), date and place of birth of each reportable person.
• In the case of a legal entity that is an account holder and a reportable person:
  • the name, address, jurisdiction(s) of residence and tax identification number(s) (TIN(s)) of that legal entity.
• In the case of a legal entity that is an account holder and for which it appears that only one person is a reportable person:
  • the name, address, jurisdiction(s) of residence and tax identification number(s) (TIN(s) of that legal entity.
• In the case of a legal entity that is an account holder and for which it appears that more persons who are beneficial owners of the account are reportable persons:
  • the name, address, jurisdiction(s) of residence and tax identification number(s) (TIN(s) of that legal entity;
  • the name, address, jurisdiction(s) of residence, tax identification number(s) (TIN(s)), date and place of birth of each reportable beneficial owner.
• Other information (concerning individuals and legal entities) to be communicated relate to:
  • account numbers,
  • the balances of the accounts at 31 December of the fiscal year of the report or at the account closure date,
  • gross interests total: total of the basic interests and fidelity premium on savings accounts and bond coupon amounts before tax deduction,
  • gross dividends total: total amount of dividends (shares, funds, trackers, etc.) received on securities account before tax deduction,
  • gross proceeds total: the total gross proceeds from sales, redemptions and reimbursements of securities, in particular, paid or credited during the calendar year.
• If the account has been closed during the course of the year to which the data exchange relates, Keytrade Bank must communicate the identification data of the client, the total gross income and proceeds. With regard to the assets, Keytrade Bank must report '0.00' as the account balance and must specify that the reporting is related to a closed account.

How is this information being exchanged?

Keytrade Bank transmits annually to the FPS Finance a report containing the information on reportable accounts. The FPS Finance then communicates this data to the tax authority of the jurisdiction of tax residence.

What is the Tax Identification Number (TIN)?

A Tax Identification Number (TIN) is an identifying number used for tax purposes. A TIN may be assigned by your tax administration.

Attention: not all countries issue a tax identification number.

For further information per country on this number, please see the following links: http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-identification-numbers https://ec.europa.eu/taxation_customs/tin/tinByCountry.html?locale=en

Or contact the tax authorities of the jurisdiction in which you are a tax resident.

Which jurisdictions are participating in the automatic exchange of information as part of the Common Reporting Standard?

Some 100 jurisdictions have given their agreement on the principle of the CRS. For information to be exchanged, the jurisdiction in which the client holds the account(s) and their country of residence must both be member states of the European Union or signatories to any multilateral or bilateral agreement that provides the basis for the automatic data exchange. The list of participating countries is available on the OECD website: Signatories of the CRS Multilateral Competent Authority Agreement

What does the CRS mean for you?

The CRS obliges Keytrade Bank to collect information on account holders and beneficial owners of certain entities that are resident for tax purposes in another jurisdiction than the country where the financial institution is established. Keytrade Bank can base itself on the information and documents provided to the bank by the client at the start or in the course of the banking relationship.

When will Keytrade Bank contact you regarding the CRS?

For natural persons:

• Indicia suggest that you have your tax domicile in another CRS jurisdiction participating in the CRS, in particular:
  • a tax resident, correspondence or residential address (permanent address) in another CRS jurisdiction,
  • one or several phone number(s) of another CRS jurisdiction without having a Belgian phone number,
  • a proxy given to a person with an address in another CRS jurisdiction.
• You are a foreign resident and your information is incomplete (documents relating to your tax residence including the TIN are missing).

For legal entities: you must clarify your CRS status and / or identify your economic beneficiaries.

What to do:

• Individuals will be asked to complete a self-certification form, and send it along with all required annexes to crs@keytradebank.com.
• Legal entities should update the company's data and their beneficial owners.

These information will allow Keytrade Bank to check your tax residency.

Why would you receive an email or letter with a request for self-certification?

Keytrade Bank has indications that your tax residence could be located in another jurisdiction than Belgium.

If you are a Belgian tax resident, you receive this request for one of the 4 following reasons:

• Your personal data are incorrect or have not been yet confirmed:
  • You have moved or changed your tax status without providing all the necessary documents to validate your information
  • Your data are currently being validated.
• You gave a power of attorney to a person with a physical or postal address in another jurisdiction than Belgium. CRS requires banks to control if the holder of an account with power of attorney to a non-resident is the beneficial owner of the assets on the account.
• You have one or more telephone numbers in a jurisdiction other than Belgium and without having a telephone number in Belgium.
• You are holder/member of a joint account, an investment club or joint ownership. Keytrade Bank does not have an e-mail address of one holder/member who is potentially non-resident.

What to do:

For reasons 1, 2 and 3: complete and submit a self-certification form, and send it along with all required annexes to crs@keytradebank.com. We also recommend you to check and validate your personal data in the mobile app or by logging into our website.

For reason 4: forward the self-certification request to the relevant holder/member so that their personal data can be updated.

If you are a non-resident for Belgian tax purposes, you receive this request for one of these two reasons:

• Incomplete personal data: Keytrade Bank does not have all the necessary information to correctly declare your tax residence. Have you transmitted all documents relating to your tax residence including the TIN?
• Indications of another tax residence: Keytrade Bank has indications that you could be a tax resident in another CRS jurisdiction than the one you declared.

What to do:

We ask you to complete and send the self-certification form along with all required annexes to crs@keytradebank.com. We also recommend you to verify and validate your personal data in the mobile application or by logging into our website.

Why do you receive an annual report of information exchanged under CRS?

This report, sent for information purposes, summarizes the information concerning your accounts and income from the previous tax year.

What to do as a non-Belgian tax resident:

We ask you to verify your data.

• If the information is complete and correct, you do not need to take any action. Keytrade Bank has the necessary information to make the Common Reporting Standard (CRS) declaration.
• If the information is incorrect or incomplete: please send the self-certification form correctly completed, signed, along with all required annexes to crs@keytradebank.com. We also recommend you to verify and validate your personal data in the mobile application or by logging into our website.

What to do as a Belgian tax resident?

It is possible and you received it for one of the following reasons:

• a move or address change is in progress
• a tax identification number is incorrect or missing
• you have not validated your personal data
  • after granting a power of attorney to a person with an address in a jurisdiction other than Belgium
  • after registering as the only telephone number that of a jurisdiction other than that of your tax residence
• documents relating to your tax residence or domicile are missing or have been refused by Keytrade Bank

We ask you to provide us with correct and complete information by sending the self-certification form correctly completed, signed, along with all required annexes to crs@keytradebank.com. We also recommend you to verify and validate your personal data in the mobile application or by logging into our website.

How to send us documents with regard to CRS?

For security reasons, we cannot access external links (such as Wetransfer, cloud, etc.). We therefore invite you to send the documents directly as an attachment to crs@keytradebank.com (max 10 MB per email).