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  • FATCA News and updates

    FATCA small reporter tool (SRT)

    We have developed a small reporter tool for Foreign Account Tax Compliance Act (FATCA) reporters with up to 50 reportable individual accounts and up to 50 reportable organisation accounts.

    FATCA reporters with no reportable accounts can also use the SRT to lodge a Nil report.

    The FATCA SRT allows reporters to enter information into an Excel spreadsheet and convert the data into an XML file.

    See also:

    Providing your Australian Business Number (ABN)

    The identifier to be used by a reporting financial institution (FI) or sponsor is the Global Intermediary Identification Number (GIIN) it received from the United States of America Internal Revenue Service (IRS) at registration. The GIIN is supplied at the reporting FI and sponsor (if a sponsor is reporting) Taxpayer Identification Number (TIN) elements. We recommend a reporting FI and sponsor also supplies their ABN in addition to their GIIN.

    Supplying your ABN helps us to record your lodgment and reduces the need for us to contact you.

    Example

    <ns2:ReportingFI>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.xx.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

     

    <ns2:Sponsor>

    <ResCountryCode>AU</ResCountryCode>

    <TIN issuedBy="US">xxxxxx.xxxxx.SP.xxx</TIN>

    <TIN issuedBy="AU">(Insert ABN here)</TIN>

    <Name>XXXXXX</</Name>

    <Address>

    End of example

    Reporting sponsor GIIN correctly

    The GIIN value of a sponsoring entity is the GIIN issued to the entity when it is acting in its capacity as a sponsor. Sponsors have 'SP' in their GIIN in the following format: xxxxxx.xxxxx.SP.xxx

    If you have more than one GIIN, ensure they are provided correctly.

    Ensure the sponsor GIIN appears in the Sponsor element. The ReportingFI GIIN should appear at the ReportingFI TIN element. (The ReportingFI TIN is the GIIN issued to the entity when it registers as a ReportingFI.)

    Trustee documented trusts (TDTs)

    When reporting for TDTs, the trustee is reporting on behalf of the trust and is therefore required to register and obtain a GIIN. The trust itself is not required to obtain a GIIN.

    The trustee GIIN is reported in the Sponsor data element. The trustee’s GIIN should not be reported in the ReportingFI element.

    The details of the trust are reported in the ReportingFI element.

    The IRS FATCA XML User Guide (PDF, 1.15MB)External Link advises to leave the ReportingFI TIN field "blank", which means removed for TDTs, the TIN field in the ReportingFI element should be removed completely.

    In the SRT, the TIN cell is left blank – refer to the SRT guide.

    Note also that:

    • the sponsor element must be present and completed
    • DocRefIds should all begin with the Sponsor GIIN
    • the sponsor FilerCategory code must be ‘FATCA609’.

    Account holder United States taxpayer identification numbers (TINs)

    If the US TIN is not held for a pre-existing account holder, reporting Australian financial institutions must comply with the required due diligence actions outlined in Notice 2017-46 (PDF, 57.30KB)External Link (summarised below).

    If due diligence actions are taken the Internal Revenue Service (IRS) will not determine that there is significant non-compliance for the calendar years 2017, 2018 and 2019.

    Due diligence actions

    Reporting Australian financial institutions must:

    • get and report the date of birth of each account holder and controlling person whose US TIN is not reported
    • annually request any missing US TINs from each account holder
    • search electronically searchable data maintained by the reporting institution for any missing US TINs before reporting for the 2017 calendar year.

    How to report missing US TINs

    When lodging with the ATO, the requirements for missing US TINs differ for 2017 and 2018 reporting. If, after due diligence actions have been undertaken you have not found the US TIN, then:

    • For the 2017 year reports, you must use nine zeros (000000000) to populate the US TIN data element.
    • For the 2018 year and subsequent year reports, you must use nine capital As (AAAAAAAAA) to populate the US TIN data element.

    Consider if your system requires changes to accommodate entering alpha type characters in the US TIN data element.

    Some other countries may have already started using nine As. This may affect reporting from/for branches in other countries.

    Archiving your reports

    Previously FATCA reports received from Australian reporters were passed onto the US immediately after lodgment. If the IRS advised of any errors requiring correction, we would contact reporters to fix the errors.

    With the implementation of the Common Reporting Standard (CRS) there is a new system to receive and transmit reports for FATCA and CRS. Under this system, your FATCA reports may not be sent to the IRS until September 2018.

    Therefore, the ATO will not be advised by the IRS of any errors requiring correction until after this time. As a result, we recommend you delay archiving your report data to enable any necessary corrections.

    Wrapper headers

    From 1 January 2019, all FATCA reports must be lodged with wrapper header information. The existing functionality, which allows the lodgment of reports without a wrapper header, will be maintained until 31 March 2019.

    See also:

    Single file limitation and extension of Bulk Data Exchange (BDE) functionality

    Under the system implemented on 1 January 2018, the lodgment of FATCA files allows only a single report per file. That report should contain all of an entity's reportable accounts.

    BDE FATCA functionality which enabled the submission of a file for more than one reporting institution was decommissioned in December 2018.

    ATO FATCA News and updates bulletin

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    Last modified: 08 Jan 2019QC 56992