Common Reporting Standard (CRS)

Background

In order to help fight against tax evasion, governments around the globe have introduced a set of new information and reporting requirements for financial institutions. This is known as the Common Reporting Standard (“CRS”).

Participation is obligatory, and Manulife is required by the CRS to (1) identify where our customers are tax residents and (2) report on certain accounts and policies held directly or indirectly by tax residents in any of the participating CRS countries.

While similar in nature, the CRS is in addition to the requirements under the United States Foreign Account Tax Compliance Act (“FATCA”).

CRS requires Manulife to send the reportable information to domestic tax authorities. These authorities in turn will exchange that information automatically on an annual basis with jurisdictions of where account holders reside.

Who are impacted?

Given the broad application of the CRS, all of Manulife’s customers may be affected. Manulife will require CRS information for new customers from January 1, 2017 onwards. Manulife will contact existing customers at a later stage.

What you need to provide

For individual customer, please complete the "Tax Residency Self-Certification" section in the Personal details update form to update your Tax Residency Self-Certification or if you are updating the following information:

• Nationality/Citizenship
• New NRIC/Passport number
• New Address to another country except USA
• New Mobile number to another country except USA
• New Alternative Contact number to another country except USA

For Entity, please complete the following form(s) below and submit together with a photocopy of your supporting documents (all sides) that is issued by an authorized government body, e.g. Latest ACRA Business Profile (not more than 3 months), Certification of Incorporation etc. 

• Corporate Owner Certification form
• CRS Self-Certification form for Controlling Person, where applicable.

Where can you further find information and advice?

For general questions on CRS, please do not hesitate to contact your Manulife representative. Manulife does not provide tax advice. For further information on your tax residency, please refer to the rules governing tax residence that have been published by your national tax authority or contact your tax advisor. You can also visit the OECD Automatic Exchange of Information portal.

http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/ For more information on CRS, please refer to the Frequently Asked Questions below.

Frequently asked questions

1. What is the Common Reporting Standard ("CRS")?

In July 2014, the Organization for Economic Cooperation and Development ("OECD") released a standard, asking governments around the world to obtain certain financial account information from their financial institutions, including insurance companies, and exchange that information automatically with overseas tax jurisdictions (“"AEOI"”).

This process is known as the Common Reporting Standard ("CRS"). The CRS requires Manulife to obtain and report certain financial information from our customers to help prevent tax evasion and protect the integrity of tax systems.

2. Is CRS the same as the Foreign Account Tax Compliance Act ("FATCA")?

No. Whereas FATCA was implemented by the US government to prevent tax evasion from US tax residents, CRS was adopted by over 100 governments to essentially satisfy the same objective.

3. Why do customers have to confirm their jurisdiction(s) of tax residency?

Under the CRS, tax authorities require Manulife to obtain and report certain information relating to their customers’ tax statuses. Manulife will ask customers purchasing certain products (such as income protection, savings, and retirement products) or with a change in circumstances (such as a move to another country / jurisdiction) to certify a number of details in a process called self-certification.

4. Are all insurance companies and wealth management companies following the CRS?

Yes. All financial institutions, including insurance companies, banks and asset management businesses in participating countries are required to follow local law and comply with the Common Reporting Standard.

5. What information are customers required to provide?

Depending on the jurisdiction, you will be asked to provide the following information:

• Name
• Current resident address
• Place and date of Birth (for Individual and Controlling persons)
• Country(ies) or Jurisdiction(s) of tax residence
• Taxpayer identification number(s) ("TIN") or its equivalents
• Entity Type and place of registration/incorporation (for Entities)
• Controlling Person Type for certain Entity Types (for Controlling Persons)

6. How is the information required for CRS captured?

Customers are required to complete a CRS self-certification. CRS self-certifications may be part of the account opening documents or a separate form. The process will vary from country to country, and depending on whether customers are an entity or an individual. The CRS self-certification will cover details such as jurisdiction of tax residence, TIN and entity type.

7. When does a CRS self-certification have to be completed?

Customers purchasing a policy or opening an account on or after [January 1, 2017] are required to complete a CRS self-certification before an in-scope product or policy can be issued or an account can be opened.

Certain pre-existing customers (see question 9) are also required to complete a CRS self-certification.

If your circumstances change (for example, you change address), we may ask you to complete a new self-certification to ensure that we have correct information about your tax residence. Please refer to the definition of "change in circumstances" in question 10.

A CRS self-certification may also be required from persons receiving payments related to a financial account.

8. What is an “in-scope” product?

In-scope products, or products subject to CRS reporting, include cash value insurance contracts, depository accounts, custodial accounts, annuity contracts and certain equity or debt interests. It is important to note that certain insurance products excluded under FATCA reporting may be in scope for CRS.

9. What is a “pre-existing customer”?

You are considered to be a pre-existing customer if you held a cash value policy or shares in one of our mutual funds prior to January 1, 2017.

10. What does a “change in circumstances” mean?

A "change in circumstances" refers to situations when details relating to your tax residency may have changed since you last provided your CRS self-certification. If we identify a change of address, telephone numbers, standing instructions, we may contact you to obtain a new self-certification.

If your circumstances change and any of the information provided to Manulife becomes incorrect (including past CRS certifications), please let us know immediately and provide an updated self-certification.

11. How is a customer’s data shared with third parties?

From time to time, we may be required by local laws to provide information to the domestic tax authority where the reportable account is held by a customer. For instance, a customer of Manulife Singapore who is a tax resident of Germany would be reported by Manulife to the Inland Revenue Authority Of Singapore, which in turn would exchange such customer’s data with the German tax authority.

Please rest assured that we share this information only when required by regulators to do so.

12. What information is shared with the tax authorities?

Manulife will provide the legally required information to the tax authorities, including information in the CRS self-certification and details about products and policies a customer holds with Manulife. This may include information such as your account balances or values, and the total amount of interest or payments credited to you.

13. How is tax residency defined?

Each jurisdiction has its own rules for defining tax residency. In general, tax residence is the country in which you live or where you spend a significant amount of your time but exceptions may exist (e.g., United States and China). Special circumstances such as studying abroad, working overseas, or extended travel may cause you to be resident elsewhere or resident in more than one country at the same time (multiple residencies). Please consult your tax advisor relating to tax residency questions as Manulife does not give tax or legal advice.

14. What is a Taxpayer identification number ("TIN") and how can I find mine or obtain one?

A taxpayer identification number (“TIN”) or its equivalent is a unique number typically issued to a tax resident by a tax authority. Some jurisdictions do not issue TINs, and other jurisdictions accept national identification numbers or similar unique identifiers as valid entries on the CRS self-certification. For details, please refer to OECD website http://www.oecd.org/

15. Why does Manulife ask for a CRS self-certification even if a customer lives in the same jurisdiction they are paying taxes in?

We understand that this process may be inconvenient for some of our customers, particularly those without exposure to multiple countries or jurisdictions. However, under the terms of the CRS, we are required by regulators to identify all account holders who are account holders in CRS jurisdictions. We have designed the self-certification process to live up to those obligations while make it as efficient as possible for our customers.

If you have any suggestions about how we might make the process more efficient or effective, we would be very happy to take your feedback.

16. Why does Manulife ask for supporting documents in addition to the CRS self-certification?

The CRS due diligence procedures are mandatory and subject to local regulations. Manulife could be sanctioned if it fails to identify, collect and report information of reportable accounts to tax authorities. Therefore Manulife needs to verify the details provided by customers as part of the CRS self-certification. This verification process could include requiring address proof, copies of passports, past tax returns or other forms of evidence.

17. Can Manulife help customers to fill out the CRS self-certification?

Manulife cannot offer tax or legal advice. Unfortunately this means that we cannot advise you on how to fill out the CRS self-certification.

18. What happens if a customer refuses to provide a CRS self-certification

Like all financial institutions, we are required to collect a CRS self-certification for any in-scope product or policy.If one cannot be provided, customers are not eligible to subscribe to any CRS in-scope product or policy.

If an existing customer refuses to provide a CRS self-certification, we will assume the customer is a ‘reportable person’ based on any other indications we have, such as mailing address and phone numbers.

19. The information that customers are providing is confidential and sensitive. How will Manulife protect this information?

Manulife takes your information security very seriously and has established policies and procedures to ensure that customer information is properly protected.
We also have measures to protect your personal information in accordance with existing laws and regulations, including but not limited to controls regarding accessing, storing, processing, transmitting and handling of personal information.

20. Where can I find further information and advice?

For general questions on the CRS, please do not hesitate to contact your Manulife representative. Unfortunately Manulife cannot provide you with tax advice.
For further information on your tax residency, please refer to the rules governing tax residency that have been published by your national tax authority or contact your tax advisor. You can also visit the OECD Automatic Exchange of Information portal.