CRS form from HSBC

[ThaiPauly]

As they are a big bank I thought I would ask if anyone else has received an e-mail from them asking if you have a TIN number?

 

If you don't have a TIN number you have to give a reason why

 

A. The country where the account holder does not issue TIN's to it's residents

 

B. The account holder is otherwise unable to obtain a TIN or equivalent number (please explain why you are unable to obtain a TIN in the below table if you have selected this reason)

 

C. No  TIN is required ( note. Only select this reason if the authorities of the country of tax residence entered below do not require the TIN to be disclosed).

 

I am thinking answer C because I have never been asked for a TIN number by the Thai authorities.

 

Anyone else have any other thoughts like this or been asked to do the same thing?

 

Many thanks

[jacko45k]

I gave 'C'... then got a letter stating they knew better than me (who has lived in Thailand over 10 years) and didn't accept that answer. I also have a pile of 7 or so letters from Coventry wanting me to confirm my identity and address. My problem is it seems to be impossible to communicate with this 'Safeguard Dept' immediately or directly,  nor respond to their emails. Even talking over telephone banking suggests that department is not approachable. They keep sending me pre-paid envelopes that of course are useless in Thailand, and  have sent me forms in Thailand , telling me to complete them and drop them off at my nearest branch!

 

I have had some long telephone conversations (they called me) with Indian based guys, but it didn't seem to help matters.

 

The postal delays, 2-3 weeks, do not help and they have already put limitations on my account.

 

All because I changed my address from my late mother's house, to my Thai address. Had an account with them since they were Midland.

 

I did formally complain and got a suitable response through Internet banking, secure messaging.

Edited October 11, 2017 by jacko45k

[topt]

14 hours ago, ThaiPauly said:

Anyone else have any other thoughts like this or been asked to do the same thing?

Yes - question comes up quite regularly in the forums.

 

I have basically told a bank and a broker no I don't have as do not need to pay tax here so no need to have one, and as another responder mentioned, quite happy for them to give details to HMRC.

 

Also as a sort of throw away if you like if you get push back you could mention that although Thailand has said it will implement CRS they still need to pass the relevant legislation and the earliest date is possibly 2022.........

[khastan]

I have had both CRS forms and safeguard forms through HSBC UK recently . I also have no Tin number so I have no idea what to do now after reading the reply from jacko45k. Neither can I fulfill safeguards identification criteria, passport okay but nothing with my Thai address on it due to all utilities being in my Thai's wife's name. Neither have I got anything sent from a UK government department with my name and address on it within the last four months! It is also interesting to note that the super secure document verification site recommended by the HSBC safeguard team to prove your documents are correct by using your webcam was recently near bankruptcy and I believe was purchased by one of the co founders of face book. https://techcrunch.com/2016/03/21/identity-verification-startup-jumio-files-for-bankruptcy-will-sell-assets-to-early-backer-eduardo-saverin/ I have to say HSBC safeguard does not fill me with any confidence!

Edited October 15, 2017 by khastan
added

[rwdrwdrwd]

I got rebuffed on reason C by Citibank, but after I argued, they admitted they were wrong and allowed it.

What seemed to clinch it was when I highlighted that Thailand was not on this list (which is referenced by the document itself) http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/crs-by-jurisdiction/#T because they have not yet implemented CRS. Therefore Thailand could not possibly 'Require that the TIN' is disclosed under CRS legislation.

Edited October 16, 2017 by rwdrwdrwd

[topt]

7 hours ago, rwdrwdrwd said:

I got rebuffed on reason C by Citibank, but after I argued, they admitted they were wrong and allowed it.

What seemed to clinch it was when I highlighted that Thailand was not on this list (which is referenced by the document itself) http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/crs-by-jurisdiction/#T because they have not yet implemented CRS. Therefore Thailand could not possibly 'Require that the TIN' is disclosed under CRS legislation.

Good to have another example of that argument being accepted  

[jayboy]

On 10/11/2017 at 8:22 AM, jacko45k said:

I gave 'C'... then got a letter stating they knew better than me (who has lived in Thailand over 10 years) and didn't accept that answer. I also have a pile of 7 or so letters from Coventry wanting me to confirm my identity and address. My problem is it seems to be impossible to communicate with this 'Safeguard Dept' immediately or directly,  nor respond to their emails. Even talking over telephone banking suggests that department is not approachable. They keep sending me pre-paid envelopes that of course are useless in Thailand, and  have sent me forms in Thailand , telling me to complete them and drop them off at my nearest branch!

 

I have had some long telephone conversations (they called me) with Indian based guys, but it didn't seem to help matters.

 

The postal delays, 2-3 weeks, do not help and they have already put limitations on my account.

 

All because I changed my address from my late mother's house, to my Thai address. Had an account with them since they were Midland.

 

I did formally complain and got a suitable response through Internet banking, secure messaging.

What kind of limitations did they put on your account? I'm surprised they are permitted to put any restrictions.

[jacko45k]

54 minutes ago, jayboy said:

What kind of limitations did they put on your account? I'm surprised they are permitted to put any restrictions.

They said my ATM card had been restricted to a max £50/day withdrawal.

I complained a lot, they gave me a bit of money and said there was now a 'normal' limit.

[jayboy]

11 minutes ago, jacko45k said:

They said my ATM card had been restricted to a max £50/day withdrawal.

I complained a lot, they gave me a bit of money and said there was now a 'normal' limit.

You were quite right to complain and I'm glad to hear all is back to normal.

[ThaiPauly]

I just got an e-mail from HSBC saying they do not accept my argument and want to know why I pay no tax in Thailand? I gave them my NI number so they could see that I was registered to pay tax in the UK.

 

They are not accepting this and want a letter from the tax office saying I don't need to pay tax in Thailand.

 

Despite me getting very angry as I had discussed this with my Relationship Manager, they are still not accepting it and say there will be "implications" if I don't do as they as they ask.

 

What a pain in the ass they are

[KittenKong]

On 11/10/2017 at 8:06 AM, ThaiPauly said:

I am thinking answer C because I have never been asked for a TIN number by the Thai authorities.

 

They wont ask you for one: you need to ask them for one.

 

I've been giving mine to various UK banks when they ask about CRS. No big deal.

[Once Bitten]

I recently received a letter from HSBC safeguard requesting that I fill out the enclosed form and return it within 14 days of the letters date . The letter took several weeks to arrive at my Thai address and the 14 days return request date was now not possible . 

 

I sent the completed form back with a letter outlining why my reply would be late . Two weeks later I received yet another same letter requesting the same form , and if I did not comply there may be restrictions put on my HSBC bank account .

 

I then went onto my HSBC bank account secure web page and selected the Chat option . I outlined to the chat operator my concerns about restrictions being placed on my bank account along with my explanation for the completed form being late in replying .

 

The chat operator put me on hold , when they came back they said that the safeguard department had now received my completed form . I then asked do I have to fill out the second form as well . The operator said no , but that I had to contact the safeguard team and talk to them . 

 

The chat operator gave me a phone number and said when some one answers , you  ask to be put through to the safe guard team .  So I called the telephone number provided by the chat operator , and after waiting over twenty minuets to be put through to the safeguard team , I managed to speak to some one . On explaining my situation regarding my completed safeguard form and why it was not returned within the require 14 day period , the safeguard operator told me that I was now speaking to the wrong department.

 

The operator who I was speaking to gave me a yet another new telephone number for the safeguard team . So a day later I telephoned the new safeguard team number and again waited and waited to be put through .  

 

Finally some one answered and I started to once again explain things .  Then the operator said , sorry you are talking to the wrong safeguard team department !!! . By this time I was not in a good mood and let rip with what I had been going through trying to talk to some one in the HSBC safeguard  department .

 

Again I was given yet another third telephone number for the safeguard team department . A day later I finally managed to speak to a lady in the correct safeguard department and she confirmed that my completed form had in fact been received , but that I now needed to answer a set of extra questions
relating to my bank account and personal details . I answered the questions and the lady assured me that there would be no further immediate letters from the safeguard team requesting that I fill in a form , she did say that I may receive in the future same form request letter , but it would in 3 – 5 years time.

 

Having just gone through the torture mill of being given the wrong telephone numbers  I decided to go back to my HSBC  bank account secure web page and open a chat conversation outlining my unhappiness at what I had just experienced . The chat operator said that they would pass on my concerns . So I just thought Oh well that's gone in the rubbish bin and to forget it .

 

One week later I received in my HSBC bank account a credit payment that I did not recognize , I got back on the chat option and queried that credit payment . The £ 50.00 credit was from HSBC as compensation for my recent problems  

 

Even after all the above , on my HSBC secure bank account web page there is still a safeguard banner saying in big letters – Update your Information Now .

 

 

A week later I received a CRS form from HSBC requesting that I fill it out and return it . I did  
vaguely recall filling out a TIN application form around the year 2007 . So I completed the form and emailed it back to the email address provided , and outlined that I had a TIN number , but as it was so long ago when I received it , I could no longer find the paperwork showing the number .

 

So far Ive not had an email / letter back advising me that my completed form was not accepted .

 

Only time will tell 

[partington]

6 hours ago, ThaiPauly said:

I just got an e-mail from HSBC saying they do not accept my argument and want to know why I pay no tax in Thailand? I gave them my NI number so they could see that I was registered to pay tax in the UK.

 

They are not accepting this and want a letter from the tax office saying I don't need to pay tax in Thailand.

 

Despite me getting very angry as I had discussed this with my Relationship Manager, they are still not accepting it and say there will be "implications" if I don't do as they as they ask.

 

What a pain in the ass they are

Your NI number isn't relevant as it doesn't show you don't have to pay tax in Thailand. It is possible to owe taxes in two countries at once or even more!

 

The simplest answer to your problem is go to your nearest tax office and ask for a Thai tax number. I did this purely to satisfy CRS requirements even before applying for a bank account and it took 30 min.

 

I just said "I need for bank" , not even saying which bank or where, and they had no problems.  (You could need it for example to get tax refunds from a Thai bank account,  you don't have to be working).

 

They give you the card and number on the spot, and mine has been sitting in a drawer unused for anything for over a year now.  But it saves problems with offshore banks just to accept you need one from now on and get it. It doesn't even matter to them  that Thailand has not signed up to CRS and probably won't for two more years at very least.

 

Things are not going to get easier in banking, and stringency is going up not down.  In 2018 all UK banks are going to be required by law to establish whether their clients have a right to stay in the UK. I imagine when this starts it will create some problems for expats too...

[Once Bitten]

8 minutes ago, partington said:

Your NI number isn't relevant as it doesn't show you don't have to pay tax in Thailand. It is possible to owe taxes in two countries at once or even more!

 

The simplest answer to your problem is go to your nearest tax office and ask for a Thai tax number. I did this purely to satisfy CRS requirements even before applying for a bank account and it took 30 min.

 

I just said "I need for bank" , not even saying which bank or where, and they had no problems.  (You could need it for example to get tax refunds from a Thai bank account,  you don't have to be working).

 

They give you the card and number on the spot, and mine has been sitting in a drawer unused for anything for over a year now.  But it saves problems with offshore banks just to accept you need one from now on and get it. It doesn't even matter to them  that Thailand has not signed up to CRS and probably won't for two more years at very least.

 

Things are not going to get easier in banking, and stringency is going up not down.  In 2018 all UK banks are going to be required by law to establish whether their clients have a right to stay in the UK. I imagine when this starts it will create some problems for expats too...

 

That's interesting as I did get a Thai Tax number to reclaim some tax back from a savings account .

 

So if the CRS do come back to me and say , sorry we can't find your TIN number , then in some way I can use my Thai Tax Number . 

[partington]

48 minutes ago, Once Bitten said:

 

That's interesting as I did get a Thai Tax number to reclaim some tax back from a savings account .

 

So if the CRS do come back to me and say , sorry we can't find your TIN number , then in some way I can use my Thai Tax Number . 

I don't understand what you mean. What is the TIN you applied for and lost details of?

 

TIN just means tax identification number.  In the UK this is simply your National Insurance number, in the US this is your social security number, and in Thailand this is your tax ID that you got for reclaiming the savings account tax.

 

If you are connected to two different countries you put in the two corresponding TINs  (I put my UK National Insurance number and my useless and unused Thai Tax ID number).  You can put 5 or 6 TINs in if you want.

[topt]

On 11/11/2017 at 2:53 PM, partington said:

TIN just means tax identification number.  In the UK this is simply your National Insurance number,

Just a query but is it the NI no. or would it be your UTR - Unique tax payer reference?

I know HMRC can get that from your NI anyway but I thought the UTR was the UK TIN?

[ThaiPauly]

It's got nothing to do with the UK topt, what they want is your TIN number in Thailand, and as suggested this can be obtained from your local tax office, so it's not that much hassle (thankfully).....(hopefully)

[partington]

33 minutes ago, topt said:

Just a query but is it the NI no. or would it be your UTR - Unique tax payer reference?

I know HMRC can get that from your NI anyway but I thought the UTR was the UK TIN?

Either will do. Information on what constitutes a TIN in various countries can be found here

http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-identification-numbers/

 

 

EDIT: You will notice that Thailand isn't on the list of countries given here for TIN information. This is because Thailand hasn't signed up to CRS: the banks' requirements for Thai TINs is therefore not even lawful or necessary- they don't care, they just demand them anyway.

 

Here is an excerpt from section on UK:

 

 

Edited November 12, 2017 by partington

[topt]

1 minute ago, partington said:

Either will do. Information on what constitutes a TIN in various countries can be found here

http://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-identification-numbers/

 

Here is an excerpt from section on UK:

 

 

thanks

[ELVIS123456]

HSBC got a serious smack from the US banking authorities. After years of fines they were basically told to get their house in order or they will be 'de-banked'.  Their response has been all sorts of new customer identity and verification procedures.  They were the 'preferred' bank for money laundering in certain areas/countries. 

 

They demanded I provide information about myself that was in breech of Aust privacy laws (informal confirmation from Agency) and I refused - so they locked my account. Once I had won and they re-opened the account (about 1 month later) I transferred out all but $0.20 and it has been idle ever since.  I guess one day they will eventually close it and keep the money, but every month they send my statement and all their other marketing crap, and I am happy to know I am causing them a net loss.  Been nearly a year now and I hear it will take 7 years before they can close it. 

 

[Monkie Business]

My HSBC bank account is a joint account with me and my thai wife , I have a Thai TIN but my wife does not work or pay tax so she does not have a TIN - what should my wife put on the CRS form ? 

[dabhand]

6 minutes ago, Monkie Business said:

My HSBC bank account is a joint account with me and my thai wife , I have a Thai TIN but my wife does not work or pay tax so she does not have a TIN - what should my wife put on the CRS form ? 

This might help.

 

https://home.kpmg.com/th/en/home/insights/2017/02/th-tax-in-focus-160217.html

Non-Thai individuals would need to register, if not done so by your employer in Thailand, with the Revenue Department to request a 13-digit Thai tax ID number. Depending on the location of the tax office where you register, it can take 2-3 business days to process your Thai tax ID number.
Thai nationals can use the Thai ID numbers on their Thai Identification Card. 

[partington]

2 hours ago, ELVIS123456 said:

HSBC got a serious smack from the US banking authorities. After years of fines they were basically told to get their house in order or they will be 'de-banked'.  Their response has been all sorts of new customer identity and verification procedures.  They were the 'preferred' bank for money laundering in certain areas/countries. 

 

They demanded I provide information about myself that was in breech of Aust privacy laws (informal confirmation from Agency) and I refused - so they locked my account. Once I had won and they re-opened the account (about 1 month later) I transferred out all but $0.20 and it has been idle ever since.  I guess one day they will eventually close it and keep the money, but every month they send my statement and all their other marketing crap, and I am happy to know I am causing them a net loss.  Been nearly a year now and I hear it will take 7 years before they can close it. 

 

I despise those bastards at HSBC, and once I am back in my home country I will do exactly as you have done for the same reasons.

 

I have never in my life encountered such an incompetent slow-witted bunch of idiots as I experienced at HSBC Expat, and if I can cost them money for seven years in a row I will gladly do so.!

Edited November 13, 2017 by partington

[partington]

2 hours ago, Monkie Business said:

My HSBC bank account is a joint account with me and my thai wife , I have a Thai TIN but my wife does not work or pay tax so she does not have a TIN - what should my wife put on the CRS form ? 

 EDIT: Deleted my original post, as post #22  above says she can use her Thai ID card number as a TIN, and this is a better solution than the one I suggested.

Edited November 13, 2017 by partington

[orientalist]

On 11/11/2017 at 6:40 AM, ThaiPauly said:

I just got an e-mail from HSBC saying they do not accept my argument and want to know why I pay no tax in Thailand? I gave them my NI number so they could see that I was registered to pay tax in the UK.

 

They are not accepting this and want a letter from the tax office saying I don't need to pay tax in Thailand.

 

Despite me getting very angry as I had discussed this with my Relationship Manager, they are still not accepting it and say there will be "implications" if I don't do as they as they ask.

 

What a pain in the ass they are

 

I guess their reasoning (if they have any!) is that by law residents of Thailand are supposed to pay tax on their income, including overseas income. But, as we all know, the Revenue Dept has never hassled retirees about this and most don't have a Thai tax number.

[jayboy]

 
I guess their reasoning (if they have any!) is that by law residents of Thailand are supposed to pay tax on their income, including overseas income. But, as we all know, the Revenue Dept has never hassled retirees about this and most don't have a Thai tax number.

Is not the liability you refer to limited to income earned in the relevant tax year and remitted to Thailand in that year? In other words is it correct that funds remitted to Thailand drawn from past years savings would not be taxable in Thailand.

As you say in practice pensioners don’t complete a Thai tax return.But given the way the wind is blowing would it be sensible - for those who have capital - to remit from that base rather than current income?


Sent from my iPhone using Thailand Forum - Thaivisa mobile app

[orientalist]

Yes. According to various accounting firms and old topics on Thaivisa (though not mentioned in the English version of the Thai tax code) , it only applies to overseas revenue earned and remitted in the same tax year.
For safety, I store my pension and transfer to Thailand the following year.

Sent on the move with my mobile phone. Please excuse the brevity.

[Mattd]

15 hours ago, partington said:

 EDIT: Deleted my original post, as post #22  above says she can use her Thai ID card number as a TIN, and this is a better solution than the one I suggested.

A Thai's ID number is their TIN by default.

As has been mentioned in the thread, anybody can get a Thai TIN issued by the revenue department, a lot of folks do in order to claim any tax deducted from bank interest.

For those worried about the CRS form, then perhaps that would be the best way to go, obtain a TIN here and provide your bank with this.

 

I do actually work and pay Thai income tax, when I got the CRS Tax residency letter from Lloyds Bank, then I gave them all this info, plus copies of work permit, residency letter from the British Embassy etc. this was initially rejected by Lloyds, so I rang them and asked why and what was I supposed to provide them with, the lady on the phone was actually really nice and took my details there and then, after which she told me that all was done and if I get anymore letters off them to just ignore them!

 

The worst thing that the banks can do is inform HRMC, for most this should not be an issue, I cannot see that they can do anything with your account and if they did then there are grounds to complain, especially if the account has been held for a long time and was opened whilst resident in the UK at that time, there are no such rules for Lloyds (example) as to having to be resident in the UK after the account is already open.

[partington]

1 hour ago, Mattd said:

A Thai's ID number is their TIN by default.

As has been mentioned in the thread, anybody can get a Thai TIN issued by the revenue department, a lot of folks do in order to claim any tax deducted from bank interest.

For those worried about the CRS form, then perhaps that would be the best way to go, obtain a TIN here and provide your bank with this.

 

I do actually work and pay Thai income tax, when I got the CRS Tax residency letter from Lloyds Bank, then I gave them all this info, plus copies of work permit, residency letter from the British Embassy etc. this was initially rejected by Lloyds, so I rang them and asked why and what was I supposed to provide them with, the lady on the phone was actually really nice and took my details there and then, after which she told me that all was done and if I get anymore letters off them to just ignore them!

 

The worst thing that the banks can do is inform HRMC, for most this should not be an issue, I cannot see that they can do anything with your account and if they did then there are grounds to complain, especially if the account has been held for a long time and was opened whilst resident in the UK at that time, there are no such rules for Lloyds (example) as to having to be resident in the UK after the account is already open.

This is all quite correct except for the banks not being able to do anything. They can simply close your account. Depending on your need for it and use you make of it this can represent  a serious problem.

 

Most banks in their terms and conditions have a clause saying they can close accounts for no reason or any reason. Complaining usually does not do anything and can take many months or years and the damage is done.

 

See for example Barclays decision to simply close accounts of expats living in Cyprus a few years back.

http://cyprus-mail.com/2015/07/22/expats-left-reeling-as-barclays-close-accounts-under-100000/

[Mattd]

2 minutes ago, partington said:

This is all quite correct except for the banks not being able to do anything. They can simply close your account. Depending on your need for it and use you make of it this can represent  a serious problem.

 

Most banks in their terms and conditions have a clause saying they can close accounts for no reason or any reason. Complaining usually does not do anything and can take many months or years and the damage is done.

 

See for example Barclays decision to simply close accounts of expats living in Cyprus a few years back.

http://cyprus-mail.com/2015/07/22/expats-left-reeling-as-barclays-close-accounts-under-100000/

This article refers to closing Barclays Cyprus accounts and not UK based accounts.

 

I would agree that a bank could possibly deem to close an account, but normally would need to have sufficient reasons to do so.

It is doubtful that a person's non-conformance to CRS would be reason, the only reason the banks are panicking to get this info is due to the deadline set by the UK Government to have this all in place by 31st December 2017 for individual accounts of less than 250,000 USD or the equivalent local currency.

The attached goes a long way to explaining.

Understanding CRS.pdf