Some, perhaps most of us involved in the submission of CRS reports, will have felt that rollercoaster of emotion following that last click of a button to complete our AEOI reporting for another year, where the sense of relief, calm and celebration as another stressful period of gathering information and figures for reporting comes to an end is followed by that moment of panic and frustration when an error in the submissions is flagged.
Human error, late replies, fresh information coming to light, whatever the reason for it, the end result is the same…put the champagne back on ice and get back to work!
Following the move from the previous version of HM Government of Gibraltar’s AEOI portal we have now received clarity as to how to submit reports correcting historical errors and delete historical files.
Whilst it is not possible to submit “correction files” since the data originally submitted is not available on the current platform, the corrections will need to be made through the submission of new data files and the Gibraltar Competent Authority has confirmed the text which should be used to notify the receiving jurisdiction that the file is being submitted as a correction (as set out in paragraph 24 of the AEOI: CRS & FATCA – Reportable Jurisdictions & Explanatory Notes - HM GoG AEOI Portal Login (egov.gi)).
With respect to the deletion of historical files, the Gibraltar Competent Authority will need to be provided with a list of the file which Financial Institutions wish to have deleted and will then contact the relevant partner jurisdiction in order to request their deletion.
It is important to note that in both instances this only applies to instances where the CRS data being corrected or deleted relate to the 31st December 2018 reportable period and earlier.