Tax Residency Self-Certification Form

The Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) are global frameworks aimed at preventing tax evasion by facilitating the exchange of financial information between countries.

• FATCA: Introduced by the US Internal Revenue Service (IRS) in 2014, FATCA requires financial institutions outside the United States to identify and report information about US taxpayers or citizens.
• CRS: Developed by the Organisation for Economic Co-operation and Development (OECD), CRS became effective in 2016 and requires financial institutions to report information about customers whose tax residence is outside the country where their account is held.

Financial institutions must collect and report information about individual account holders, entities, and controlling persons of certain entities.

A Tax Identification Number (TIN) is a unique identifier issued by a tax authority to individuals or entities for tax reporting purposes.

• In the UK, this is typically the National Insurance number or the Unique Taxpayer Reference (UTR) number.
• In the US, this could be a Social Security Number (SSN) or Employer Identification Number (EIN).

If you are unsure about your TIN, check with your local tax authority or consult your financial advisor.

To complete the Tax Residency Self-Certification form, you may need to provide:

• The CIN associated with each of your VCT holdings under City’s administration
• Your full name and address
• Your date of birth, place of birth (town/city) and country of birth
• Your country or countries of tax residence (incl. UK)
• Your Tax Identification Number (TIN) for each tax jurisdiction (incl. NINo or UTR)

Financial institutions are required to collect self-certification forms to determine their account holders' tax residency under FATCA and CRS regulations. The form ensures accurate reporting to local or international tax authorities.

Regarding your VCT shareholding, per the relevant regulations, the VCT is a ‘reportable financial institution’, your shareholding is an ‘account’, so you are an ‘account holder’.

Failure to provide the requested information may result in your account being incorrectly reported to the relevant tax authorities.

Yes, each joint holder is required to complete and submit a separate Tax Residency Self-Certification form.

This is because tax residency is specific to each individual, and reporting obligations apply to all account holders independently.

If any joint holder does not provide the required information, the account may still be reported based on the information provided by the other holders or existing data held by the financial institution.

The timeframe to complete the form is typically specified in the request you receive from your financial institution.

It's important to respond promptly to avoid delays in processing or the possibility of your account being reported incorrectly. If you're uncertain about deadlines, contact your financial institution for clarification.

Yes, the regulations generally require reporting on accounts that were active during the reporting year, even if they have been closed before the end of that year.

The reporting year follows the calendar year (1 January to 31 December). Financial institutions must submit their annual report to HMRC by May 31 of the following year. This means that if you held shares at any point during the calendar year, the financial institution needs your self-certification to determine whether your account is reportable, even if you have subsequently sold your shares.

Yes, a certification may still be required. If the shareholder held shares at any point during the reporting year (which follows the calendar year) before their passing, their account information would be included in the financial institution’s return to HMRC.

In this situation, the executor or administrator of the estate should complete the self-certification form on behalf of the deceased shareholder, providing the tax residency information of the deceased person as it was prior to their death. The form should be signed by the executor/administrator indicating they are acting in that capacity.

We understand this may be a difficult time, and we're happy to provide any additional guidance needed to help executors fulfil this regulatory requirement.

If your account details are reportable under FATCA or CRS, the financial institution will share:

• Your full name, address, and date of birth
• Your country or countries of tax residence
• Your Tax Identification Number (TIN) for each tax jurisdiction
• Account details, including balances, payments, and income generated

This information is reported to the local tax authority annually, typically by the financial institution's reporting deadline. The local tax authority then exchanges this information with relevant tax authorities internationally.

If your financial institution confirms that your details are not reportable under FATCA or CRS after you've self-certified, no further action is required.

However, it's important to notify your financial institution if your tax residency changes in the future, as this may affect reporting obligations.

If you do not complete the self-certification form, the financial institution may need to classify and report your account based on existing data from the statutory register of members, which may exclude your DoB, tax residency countries and associated TINs (incl. NINo/UTR).

This could result in your account being incorrectly reported to tax authorities.

If you need further details or guidance, please visit the following resources or consult a tax professional:

• OECD CRS Information
• HM Revenue & Customs (HMRC)
• US Treasury FATCA Information