Virgin Islands Financial Institutions (VIFIs) under the Common Reporting Standards (CRS) and Virgin Islands Constituent Entities (VICEs) for Country by Country Reporting (CBCR) are notified that the BVI Financial Account Reporting System (BVIFARS) is still in the process of being updated.

As a result, the reporting deadline for financial institutions that qualify as Trustee Documented Trusts (TDT) under CRS and has reportable accounts for 2018 has been extended to June 28.  

Trustees that have already registered their documented trusts on the BVI reporting system are advised to follow the instructions in the recently published Guidance Notes on the Common Reporting Standards and submit the filings via the TDT accounts. Trustees who have not yet registered their documented trusts on BVIFARS and are waiting for the system to be updated are advised to submit their TDT filings via their Trustee’s account.

The Common Reporting Standards require the Trustee’s Documented Trusts to be identified, therefore, their information must be inserted in the Reporting FI Section of the report when preparing the filing via the Trustee account.  This provision for TDTs to report via their Trustee’s account is for the reporting year 2018.  A copy of the Guidance Notes for Common Reporting Standards is accessible on the website:  www.bvi.gov.vg/aeoi-crs.  

Reporting Financial institutions are also reminded that it is now mandatory for those entities that do not maintain any reportable accounts, to submit a nil report.

As it relates to VICEs for CBCR the period for enrolment via email is being extended. All VICE are advised that they should continue to register via email as instructed in the recently published Guidance Notes for Country by Country Reporting until they are advised that the system is ready to accept their registration or enrolment applications and filings.  These entities should consult the Guidance Notes to obtain the correct format to submit your email registration applications.  A copy of the Guidance Notes for CBCR is accessible on the website:  www.bvi.gov.vg/aeoi-beps.

As the ITA has received a number of requests for a test window to submit test data before filing, the ITA wishes to inform all entities that BVIFARS is a live system and only actual data to be transmitted to the reporting jurisdictions should be submitted in the system; The following deadlines for US FATCA, CRS and CBCR as stated herein for the reporting year 2018:

• Reporting Virgin Islands Financial Institutions, enrolment or registration deadline for US FATCA was April 1 and for the Common Reporting Standards (CRS) it was April 30.
• Virgin Islands Financial Institutions filing deadline for 2018 Reportable Accounts, (except reportable accounts for TDTs) is May 31. This filing deadline is applicable for both US FATCA and CRS. 
• Nil Reports for CRS the filing deadline is also May 31 for all reporting VIFIs (except reportable accounts for TDTs).
• Trustee Documented Trusts with reportable accounts for 2018, the extended filing deadline is June 28.  If there is nothing to report, a nil filing is also to be submitted no later than June 28.
• All Non-Reporting Virgin Islands Financial Institutions, enrolling or registering for CRS, the registration period has been extended and a further Press Release shall be issued to inform Non-reporting VIFIs when the system is ready to accept their applications.  Non-reporting VIFIs are not required to register until the system has been configured to accommodate such enrolments and this includes TDTs.  When the system is ready, they will be notified of the new extended deadline to complete the registration process.
• Virgin Islands Constituent Entities enrolment or registration for Country by Country Reporting; has been extended to allow VICE to continue to satisfy their registration requirements via email registration and a further Press Release shall be issued to inform VICEs when email registrations will come to an end and when applications will be accepted via BVIFARS. 
• Virgin Islands Constituent Entities eligible for reporting, whether as a Parent Entity or Surrogate Entity under the Country by Country Reporting requirements, the first reporting shall be December 31 and thereafter as stated in the MLA.  All reporting is to be completed via BVIFARS, which is expected to be ready in advance of the first reporting period.

For more information on the International Tax Authority, please contact the International Tax Authority via telephone: 1 (284) 468 4415 or email: BVIFARS@gov.vg.