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The following checklist highlights issues your financial institution may need to review to ensure your systems remain fit for purpose.

  1. Does your enterprise-wide tax governance process cover sufficiently the CRS system (including reporting to senior management or the board of directors)?

  2. Are your CRS policies, procedures and controls documented fully and periodically tested or reviewed for any changes that have taken place?

  3. Have you maintained technical training (especially of new staff members with responsibilities pertaining to CRS work) and retained subject matter experts to answer the more difficult issues that arise?

  4. Do you have back-up plans where there is considerable reliance placed on one or two key individuals?

  5. Do you maintain quality controls when CRS system functions are outsourced offshore, especially given that New Zealand financial institutions have ultimate responsibility for complete and accurate CRS record-keeping, due diligence, and reporting?

  6. Do you maintain documentation as to steps undertaken and evidence relied upon for performance of CRS due diligence procedures, including the identification and actions taken in respect of false certifications?

  7. Are self-certifications obtained every time a new account is opened and their reasonableness confirmed?

  8. Are you still monitoring effectively for changes in circumstances in relation to the identity or reportable status of account holders and/or controlling persons?

  9. Are you collecting tax identification numbers (TINs), dates of birth (DoBs) and full addresses for account holders (and controlling persons) as well as making reasonable efforts to collect TINs and DoBs for pre-existing accounts not already in your records?

  10. Are trusts (including family trusts) properly classified and reported (including the reporting of account holders and controlling persons of the trust)? You can find out more in 'Is the trust a Reporting NZFI under CRS? - IR1052' and 'Family trust obligations under the CRS - IR1053'.

  11. Are undocumented accounts properly classified, reported and reducing in volume?

  12. Are you keeping a watchful eye for potential CRS circumvention arrangements when opening a new account, such as the misuse of citizen/residence by investment schemes?

Residence/Citizenship by investment - Organisation for Economic Co-operation and Development (

If you identify deficiencies in your CRS reporting we can work with you to fix the issue, email us at  [email protected]

If we identify material errors or omissions through the compliance activities we initiate then penalties will need to be seriously considered.

Last updated: 17 Apr 2023
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