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CRS registration and reporting

This page explains how reporting New Zealand financial institutions (NZFIs) can register with us for the Common Reporting Standard (CRS), and the reporting options available for annual disclosures.

The following registration requirements also apply to trustee documented trusts that have reportable accounts. This is a high level summary with some exceptions.

Important

If your tax agent has your official written authority to act on your behalf, they'll be able to register and report for the CRS for you.

Service providers and trustees will be able to report on behalf of an NZFI for CRS purposes. They will not be able to register unless they are a tax agent.

The NZFI will be able to delegate access to service providers and trustees in myIR. Alternatively, the service provider or trustee will be able to request access from the NZFI.

Registering for the CRS with us

NZFIs with CRS obligations are able to register in myIR.

Register for a myIR account if you don't have one already

Our Common Reporting Standard (CRS) - registration and reporting user guide assists you with the registration and reporting process.

What information is required to register

Before you register for the CRS, you'll need to have an IRD number.

If you don't meet the criteria to apply for an IRD number, email us at global.aeoi@ird.govt.nz to discuss your situation.

We'll ask you some questions to determine if the entity you're registering is an NZFI that needs to report to us for CRS purposes.

Question 1: Are you a Financial Institution?

Yes: Go to question 2.

No: You must be a financial institution to register for a CRS account.

Description

A financial institution is a type of entity.

An “Entity” covers legal persons and legal arrangements, eg, companies, corporations, partnerships, incorporated bodies, trusts and foundations. An individual cannot be an “Entity”.
CRS section VIII(E)(3).   

A “Financial Institution” is an Entity that comes within any of the following four categories:

  • Investment Entity – this includes Entities that satisfy either of the following:
    • the Entity’s income is derived, mainly (50% or more) from carrying on a business of providing specified investment activities for customers (such as portfolio management, investment, or administering financial assets or money for customers); or
    • the Entity’s income is derived mainly (50% or more) from financial assets (such as shares and bonds – cf real property) and the entity is managed by another financial institution (such as a financial institution corporate trustee or fund manager). 
  • Depository Institution – generally includes savings banks, commercial banks, savings and loan associations and credit unions
  • Custodial Institution – generally includes custodian banks, brokers and central securities depositories that derive 20% or more of their income from holding financial assets (such as shares and bonds – cf real property) and providing related services for customers, and
  • Specified Insurance Company (generally an entity that issues or makes payments with respect to cash value insurance products).

CRS Section VIII(A) of the CRS and CRS Com pp. 159-165

Question 2: Is the Financial Institution in New Zealand?

Yes (resident in New Zealand or branch in New Zealand): Go to question 3.

No: You must be a financial institution that is resident in New Zealand (or has branch operations here) to register for a CRS account.

Description

  • Generally a Financial Institution will be resident in New Zealand for CRS purposes if it is resident in New Zealand for tax purposes.
  • However, the following special rules apply for Financial Institution trusts (other than unit trusts) and other types of entities that do not have a tax residence.
  • Where a Financial Institution is a Trust, it will generally be resident in New Zealand for CRS purposes if one of the Trustees is a NZ tax resident. [However, an exception to this is if the trust has a trustee overseas and reports for CRS purposes in that country because the trust is tax resident in that country – in which case the Trust will be treated as resident in that other country (not New Zealand) for CRS purposes].
  • Where a Financial Institution (other than a Trust)  does not have a tax residence, it is treated as resident in New Zealand for CRS purposes if any of the following apply:
    • the Entity is incorporated in NZ,
    • the Entity has a place of management in New Zealand; or
    • the Entity is subject to financial supervision in New Zealand.
  • Multiple Residence Entities (except Trusts): Place where the accounts are maintained. For example, where such an entity is resident in two or more countries (including New Zealand) the Entity will be subject to CRS obligations in New Zealand for accounts maintained in New Zealand.

CRS Section VIII(A)(2) and CRS Com. pp. 158-159.

Question 3: Are you excluded from reporting either by the Common Reporting Standard or by Inland Revenue?

Yes: You have determined that you are a category of financial institution that is not required to report (or be reported on) for CRS purposes. You do not need to register for a CRS account.

No: Registration complete. Please note that trustee documented trusts with reportable accounts are required to register with IRD.

Description

Non-Reporting Financial Institutions include:

  • Certain Governmental Entities (Com pp. 166-167);
  • Certain International Organisations (Com pp. 166-167);
  • Central Bank (Com pp. 166-168);
  • Broad Participation Retirement Fund (Com p. 168);
  • Narrow Participation Retirement Fund (Com pp. 168-169);
  • Pension Fund of a Governmental Entity, International Organisation or Central Bank; (Com p. 169);
  • Qualified Credit Card Issuer (Com pp. 169-170);
  • Exempt Collective Investment Vehicle (Com pp.173-174);
  • Trustee-Documented Trust (Com p. 174) – Please note that a trustee documented trust does not need to report for CRS purposes. However, this is provided that it has a financial institution trustee and that trustee reports on the trust’s behalf. Trustee documented trusts with reportable accounts are required to register with IRD.
  • Low-risk Non-Reporting Financial Institutions (Com pp. 170-173)

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Reporting CRS information to us

New Zealand Financial Institutions (NZFIs)

NZFIs with CRS obligations (including service providers and trustees that report on their behalf) are able to report the relevant CRS information to us in myIR.

You must complete your reporting by 30 June of the relevant tax year. For example, if your first CRS period ended 31 March 2018 you must report by 30 June 2018.

Instructions on how to submit a CRS disclosure are in the Common Reporting Standard (CRS) - registration and reporting user guide.

We can't provide extensions to the reporting period as this obligation is set out in the Tax Administration Act 1994. It's also important that New Zealand meets its international obligations.

You are able to choose from three different reporting options:

  1. Online form for small volume disclosures.
  2. Excel template for medium volume disclosures of up to 1,000 records (see "Note" below). You must make sure you use the appropriate version of this template when reporting. This version is available in myIR.
  3. XML for large volume disclosures with a maximum file size of 350mb.

Account holders and controlling persons

Account holders and controlling persons aren't required to report to us. Their financial institution will report the prescribed information about their accounts, if such persons are identified as being relevant foreign tax residents.

Automatic Exchange of Information: Your obligations if you hold or control financial accounts

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International exchange of information

If New Zealand has an automatic exchange of information (AEOI) exchange agreement with your jurisdiction of tax residence, we'll send this information to the tax authority in that jurisdiction by 30 September of the relevant tax year.

New Zealand will also be receiving information from other jurisdictions about New Zealand tax residents that are investing overseas. This will help us verify that these people have paid the correct tax on these offshore investments.

We'll handle all information reported under the CRS in the strictest confidence as will the foreign tax authorities. Domestic laws, administrative practices, and binding international treaties protect your information.

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Penalties for non-compliance

New Zealand Financial Institutions

Penalties can apply to financial institutions that don't comply with CRS due diligence and reporting obligations, including recordkeeping. This includes escalating thresholds of civil penalties and criminal penalties for knowledge-based offences.

Account holders and controlling persons

Penalties may apply if you:

  • provide false, incomplete or misleading information,
  • fail to provide this information, or
  • fail to provide an update if there is a material change to the information you have provided.

This includes civil penalties of $1,000 that we could apply as well as criminal penalties that can apply for knowledge-based offences.

Automatic Exchange of Information: Your obligations if you hold or control financial accounts

You can find more information in Section 9 Penalties Regime, Inland Revenue Guidance on the CRS.

Reference and support documents

Go to all our important AEOI and CRS documents