Description

BSE circular providing updated Tax Identification Number (TIN) structures and formats for individuals and legal entities across multiple countries for FATCA/CRS compliance purposes.

Summary

BSE has issued an update regarding the correct and valid Tax Identification Number (TIN) structures for FATCA (Foreign Account Tax Compliance Act) and CRS (Common Reporting Standard) compliance. The circular provides detailed TIN formats for both individuals and legal entities across 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

  • Comprehensive TIN structure reference for 16 jurisdictions provided
  • Separate TIN formats specified for individuals and legal entities
  • Some jurisdictions (Bahamas, Bermuda, British Virgin Islands) do not issue TINs
  • TIN structures vary significantly by country - ranging from 6 to 14 digits
  • Specific formatting requirements including letters, numbers, hyphens and slashes detailed
  • Country-specific validation logic and prefixes documented

Regulatory Changes

This circular provides updated reference information for FATCA/CRS compliance rather than introducing new regulatory changes. It ensures market participants have accurate TIN structure information for:

  • Validating tax identification numbers during client onboarding
  • Ensuring compliance with international tax reporting obligations
  • Proper formatting of TIN data for regulatory submissions
  • Avoiding errors in FATCA/CRS reporting due to incorrect TIN formats

Compliance Requirements

Market Participants Must:

  • Update their validation systems with correct TIN structures for each jurisdiction
  • Ensure client records contain properly formatted TINs according to country-specific requirements
  • Identify jurisdictions that do not issue TINs (Bahamas, Bermuda, British Virgin Islands) and handle accordingly
  • Validate TINs against the specified formats before submission to authorities
  • Maintain accurate FATCA/CRS documentation with correct TIN information

Key Jurisdictional Requirements:

  • Argentina (AR): 11-digit CUIT with prefix indicating person type (20=men, 27=women, 30/33=legal persons)
  • Australia (AU): 8-9 digits for individuals, 11 digits for entities
  • Brazil (BR): 11 digits for individuals (CPF), 14 digits for legal persons (CNPJ)
  • Barbados (BB): 13-digit TIN starting with “1”
  • No TIN jurisdictions: Document as “No TIN” for Bahamas, Bermuda, and British Virgin Islands

Important Dates

No specific effective date or deadline mentioned. This is a reference update for ongoing FATCA/CRS compliance obligations.

Impact Assessment

Operational Impact: High - Requires immediate update to KYC/onboarding systems and validation logic

Compliance Impact: Critical - Incorrect TIN formats can lead to:

  • Rejection of FATCA/CRS reports by tax authorities
  • Penalties for non-compliance with international tax reporting standards
  • Delays in account opening and transaction processing
  • Regulatory scrutiny and potential enforcement actions

Market Participants Affected:

  • Stock brokers and depository participants
  • Investment advisors and portfolio managers
  • Custodians and clearing members
  • Any entity with reporting obligations under FATCA/CRS

Action Required: Immediate review and update of TIN validation systems, client databases, and compliance procedures to align with the provided TIN structures.

Impact Justification

Critical compliance update for FATCA/CRS reporting requirements affecting all market participants dealing with international clients and entities across 16+ jurisdictions