BVI FATCA Compliance Deadlines Extended

This week the British Virgin Islands (BVI) announced the extension of its FATCA registration and reporting deadlines, as follows:

Compliance Obligation Old Deadline Extended Deadline
Registration June 1, 2015 June 30, 2015
Reporting June 30, 2015 July 31, 2015

Registration

Each BVI investment entity that (A) has been classified as a “Reporting BVI Financial Institution” for purposes of FATCA (or its “sponsoring entity,” if applicable), and (B) is required to file a 2014 FATCA report with the BVI government, should register with the BVI International Tax Authority (ITA) by the extended June 30, 2015 deadline in order to comply with its obligations under FATCA.1

To register, a Reporting BVI Financial Institution (or its “sponsoring entity”) must log on to the BVI Financial Account Reporting System (BVIFARS – click here) and submit a simple online form, together with PDF versions of (A) the primary user’s passport, and (B) a letter, signed by a director of the financial institution, which specifies the primary user as the financial institution’s responsible person for FATCA compliance.

Reporting

Each Reporting BVI Financial Institution (or its “sponsoring entity”) that has a reporting obligation with respect to 2014 now has until July 31, 2015 to file its 2014 FATCA report. “Nil reporting” is not required if a Reporting BVI Financial Institution had no reportable accounts in 2014.

If reporting is required, it must be completed through BVIFARS (click here). The ITA has published detailed guidance (click here) to assist with the reporting process.


1. See the Foley Adviser, dated April 16, 2015, regarding upcoming FATCA compliance deadlines (click here) for additional information.↩