Description

BSE provides updated reference guide for Tax Identification Number (TIN) structures and formats across multiple countries for FATCA/CRS compliance purposes.

Summary

BSE has issued an updated reference guide detailing Tax Identification Number (TIN) structures and formats for individuals and legal entities across multiple jurisdictions. This information is essential for compliance with Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) requirements. The circular provides comprehensive TIN formatting rules for 16 countries including Albania, Andorra, Anguilla, Argentina, Aruba, Australia, Austria, Azerbaijan, Bahamas, Barbados, Belgium, Belize, Bermuda, Brazil, British Virgin Islands, and Brunei Darussalam.

Key Points

  • Updated TIN structure information provided for multiple countries to ensure accurate FATCA/CRS reporting
  • Includes distinct TIN formats for individuals and legal entities where applicable
  • Some jurisdictions (Bahamas, Bermuda, British Virgin Islands) do not issue TINs
  • TIN formats vary significantly by country - ranging from 6 to 14 digits with different structural requirements
  • Specific formatting rules provided including use of letters, digits, hyphens, and slashes
  • Critical for proper identification and reporting of foreign account holders

Regulatory Changes

This is an informational update rather than a regulatory change. It provides reference material to assist market participants in validating and recording correct TIN information for FATCA/CRS compliance. No new regulatory obligations are imposed through this circular.

Compliance Requirements

  • Market participants must ensure they collect and validate TINs according to the structures specified for each country
  • Proper TIN formatting must be maintained in systems for accurate FATCA/CRS reporting
  • Entities should reference this guide when onboarding international clients or validating existing records
  • Where jurisdictions do not issue TINs, this should be properly documented and “No TIN” status recorded
  • Special attention required for countries with different TIN structures for individuals versus legal entities

Important Dates

No specific deadlines mentioned. This is a reference update for ongoing compliance activities.

Impact Assessment

Operational Impact: Medium - Market participants need to review and potentially update their TIN validation rules and systems to align with the provided structures. This affects client onboarding processes, data quality checks, and reporting systems.

Market Impact: Low - This is an informational circular that supports existing compliance obligations rather than creating new ones.

Affected Parties:

  • Brokers and intermediaries handling international clients
  • Custodians and depositories maintaining foreign investor records
  • Compliance and operations teams responsible for FATCA/CRS reporting
  • IT systems teams managing client data validation rules

Country-Specific TIN Structures (Sample)

Countries Without TINs:

  • Bahamas, Bermuda, British Virgin Islands - do not issue TINs

Selected TIN Formats:

  • Albania: 1 letter + 8 digits + 1 letter (same for individuals and entities)
  • Argentina: 11 digits (prefix indicates person type: 20=men, 27=women, 30/33=legal entities)
  • Australia: 8-9 digits for individuals, 11 digits for entities
  • Brazil: 11 digits for individuals, 14 digits for legal entities
  • Barbados: 13 digits starting with “1”
  • Belgium: 11 digits for individuals, 10 digits for companies

Impact Justification

Update provides critical reference information for FATCA/CRS compliance but does not introduce new requirements or deadlines. Impacts market participants dealing with international investors requiring proper TIN validation.