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FATCA form from Barcalys International


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Has anybody else received one of these?

 

https://www.home.barclays/content/dam/barclayspublic/docs/FATCA/Individual Self Certification Form 20151218 - FINAL.pdf

 

I thought FATCA was only applicable to US citizens (I'm British and have never had anything to do with living, working or owning anything in the US)? Part 2 though looks like it's asking for details about my Thai status regardless of whether I'm a 'US person' or not. Why would Barclays want that information under FATCA? I remember a few years ago I filled out a FATCA from for SCB but that was a one-off and as I'm not a 'US person' it didn't matter anyway.

 

Anybody got any idea what this new form is about, or am I reading Part 2 wrong?

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That is a Barclays form. It is not a US tax form.

This from the bottom of the last page.

 

Quote

1 The term ‘tax regulations’ refers to regulations created to enable automatic exchange of information and include Foreign Account Tax Compliance Act, various Agreements to Improve International Tax Compliance entered into between the UK, the Crown Dependencies and the Overseas Territories, and the OECD Common Reporting Standard for Automatic Exchange of Financial Account Information, as implemented in the relevant jurisdictions.

 

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50 minutes ago, phetphet said:

I also had to fill one out in the UK last year. The US extending it's power the worlds banking system, and using the opportunity to gather as much personal information as possible.

 

I filled one out for SCB a year or two back, but as I'm not a 'US person' it was a one-off and no problem. 

I'm just a bit concerned that if I give Barclays my Thai details in Part 2 they might start sending information about my offshore investments to the Thai tax authorities, event though FATCA, at least as far as I understand it, is providing information only for the IRS.

Maybe it's safest just to say that I don't have a Thai TIN?

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44 minutes ago, ubonjoe said:

That is a Barclays form. It is not a US tax form.

This from the bottom of the last page.

 

 

 

Yes, that's right, similar to the form I had to fill in a year or two ago for SCB here in Thailand.

 

Has FATCA recently been extended so that it now involves multilateral data sharing between different countries instead of just being a demand from the US to all other countries for data about their citizens?

 

The reason I ask is that this is what it says on the Barclays website:

 

"New international agreements involving a large number of countries have been coming into force recently in order to assist tax authorities to deter and detect tax evasion especially relating to assets held in countries where the owner is not resident for tax purposes.

These international agreements, when implemented, create a legal obligation requiring all financial institutions, including Barclays, to:

  • obtain extra information from customers;
  • identify a possible connection, for tax purposes, with another  country / other countries;
  • establish the tax residence of all account holders; and
  • report the financial account information for identified customers to the relevant tax authorities."

https://www.home.barclays/fatca/#forms

 

 

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Some better-informed person on another board suggested I should Google CRS EXCHANGE OF INFORMATION.

 

This should evidently be called GATCA rather than FATCA as you will see if you do the search. This article provides a good summary as far as I can tell.

 

https://profwilliambyrnes.com/2014/05/10/47-countries-endorse-oecds-gatca-crs/

 

Thailand is currently not included in the group of countries that have agreed to implement this. Still it seems that the days of the expat with a nice tax-free offshore income are well and truly numbered.

 

Any additional information would be appreciated.

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The U.S. FATCA has got most of the attention, but really numerous countries are jumping on the financial account exchange of information among countries under various agreements and laws.    Even though the OP's link had a few specific things about FATCA and U.S. citizens it really was not FATCA-specific; it was more like the financial information exchange requirement as spelled out in Guderian's post above.   Yeap, more and more countries are jumping on the financial account exchange of info "regardless of your citizenship."

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19 hours ago, Guderian said:

I'm just a bit concerned that if I give Barclays my Thai details in Part 2 they might start sending information about my offshore investments to the Thai tax authorities

 

The Thai authorities have no interest whatsoever in your offshore investments.  One doesn't include them in one's annual tax return.

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1 hour ago, Oxx said:

 

The Thai authorities have no interest whatsoever in your offshore investments.  One doesn't include them in one's annual tax return.

 

That's what I was told when I first moved here 12 years ago. This is from the RD's website (http://www.rd.go.th/publish/6045.0.html) :

 

" Taxpayers are classified into “resident” and “non-resident”. “Resident” means any person residing in Thailand for a period or periods aggregating more than 180 days in any tax (calendar) year. A resident of Thailand is liable to pay tax on income from sources in Thailand as well as on the portion of income from foreign sources that is brought into Thailand. A non-resident is, however, subject to tax only on income from sources in Thailand. "

 

Well I'm certainly 'resident for tax' here, so what exactly does this mean: "liable to pay tax  ... on the portion of income from foreign sources that is brought into Thailand". I was originally told that you had to pay Thai tax on any overseas income that was remitted into Thailand in the year that it was made. I'm guessing this was meant to cover regular pension payments made into a Thai bank account. But the way that sentence reads they might decide to tax you at Thai rates on any savings that you brought in as a lump sum as well? Anybody have a better interpretation?

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It seems that 101 countries have now signed up to this free exchange of financial information about people banking in their territories:

 

http://www.oecd.org/tax/transparency/AEOI-commitments.pdf

 

Happily Thailand is still among those who won't take part:

 

https://thebanks.eu/articles/countries-which-will-not-automatically-exchange-account-information

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And everyone should not confuse the OECD-driven CRS with the U.S.-driven FATCA.   FATCA is focused on U.S. citizens/businesses; CRS is focused the citizens/businesses of countries signed up to it.  They are two different (but similar) financial reporting instruments.  

 

And I expect many countries/financial organizations will try to kill two birds with one stone by creating account questionnaires, forms, data retrievals, and reporting that satisfies both instruments. 

 

But the handwriting is clearly on the wall....it's getting harder and harder to not report financial accounts (intentionally or unintentionally) a person or business  holds in other countries.   More countries will slowly jump on this financial information exchange bandwagon from the need to collect more tax revenue and/or to avoid negative impacts from not participating.

 

http://www.apexfundservices.com/latest-news/fatca-vs-crs-the-differences-explained

FATCA and CRS have many similar characteristics but are by no means the same. Take a look at this quick overview to fully understand the differences and impacts on fund managers.

FATCA - Foreign Account Tax Compliance Act

The Basics:

  • A US tax initiative introduced by the United States Inland Revenue Services (IRS).
  • Commitment: 100+ countries have signed up to FATCA.
  • AIM: to reduce tax evasion by US citizens and US tax residents.

CRS - Common Reporting Standard

The Basics:

  • A global tax initiative introduced by the Organisation for Economic Co-operation and Development (OECD).
  • Commitment: 90+ countries have signed up to CRS.
  • AIM: To reduce tax evasion by the taxpayers of the 90+ countries signed up to CRS.

KEY DIFFERENCES:

Registration:

FATCA: Financial institutions (FIs) must register on the IRS portal to obtain a Global Intermediary Identification Number (GIIN).

CRS: There is no requirement to register and receive a unique identifier of compliance under CRS.

Due Diligence:

FATCA:

  • FATCA aims to identify whether an account holder is a US person using citizenship and tax residency.
  • Tax information is collected for US account holders ONLY.

CRS:

  • CRS aims to identify the tax residency of each and every one of its account holders (most countries are adopting the 'wider approach' under CRS which allows Funds to collect tax information from all investors).
  • Tax information is required for ALL account holders.

Reporting:

FATCA:

FATCA requires FIs to report on US account holders ONLY.

  • Reporting requirements: Name, Address, TIN, Account Number, Name and identifying Number of FI, Account Balance, Income & Sales Proceeds phased in from 2017 for all US account holders.
  • Information must be reported on the US FATCA schema to the local Tax Authority for onward forwarding to the IRS.

CRS:

CRS requires FIs to report on almost all foreign tax residents which will result in significantly higher volumes of reporting.

The reporting requirements are the same as FATCA with the exception of:

  • Tax residency, date and place of birth are also reported for ALL account holders.
  • Information must be reported on the CRS schema to the local Tax Authority for onward forwarding to all countries complying with CRS.

Thresholds and Exemptions

FATCA:

There are less accounts in scope for due diligence and reporting under FATCA due to the minimum thresholds:

  • Pre-existing individuals <$50k and pre-existing entities <$250k (as at 30 June 2014) are not in scope for reporting until balances exceed $1m.

CRS:

There are far more accounts in scope for due diligence and reporting under CRS.

  • The only exemption threshold that applies is $250k for pre-existing entity accounts (as at 31 December 2015). Once the balance exceeds $250k then investors fall within the scope of CRS.

PENALTIES!

FATCA:

  • Compliance with FATCA reporting is a legal obligation.
  • The Fund and its directors are subject to the local jurisdictional penalties for non-compliance.
  • Monetary penalties are in place in each jurisdiction and persistent non-compliance could result in the closure of a Fund.

CRS:

  • Compliance with CRS reporting is a legal obligation.
  • The Fund and its directors are subject to local jurisdictional penalties for non-compliance.
  • Monetary penalties are in place in each jurisdiction and persistent non-compliance could result in the closure of a Fund.

For more information or support with CRS or FATCA, contact your local Apex office: Locations

 

- See more at: http://www.apexfundservices.com/latest-news/fatca-vs-crs-the-differences-explained#sthash.mq8sRdY2.dpuf

 

 

Edited by Pib
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3 hours ago, Guderian said:

I was originally told that you had to pay Thai tax on any overseas income that was remitted into Thailand in the year that it was made. I'm guessing this was meant to cover regular pension payments made into a Thai bank account.

 

Have you ever heard of someone living here's being taxed in Thailand upon their pension income? I certainly haven't.  I don't believe it happens.

 

There is, apparently, a one year rule, but I've never seen anyone providing an authoritative link proving this.  I suspect it's just bar stool mythology (but would very interested to be proven wrong).

 

The practical reality is that the Thai tax authorities have no interest in offshore investments, even if income and/or capital are brought into the country (except in very rare cases where such interest is politically motivated).

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20 hours ago, Oxx said:

 

Have you ever heard of someone living here's being taxed in Thailand upon their pension income? I certainly haven't.  I don't believe it happens.

 

There is, apparently, a one year rule, but I've never seen anyone providing an authoritative link proving this.  I suspect it's just bar stool mythology (but would very interested to be proven wrong).

 

The practical reality is that the Thai tax authorities have no interest in offshore investments, even if income and/or capital are brought into the country (except in very rare cases where such interest is politically motivated).

 

I've never worked here and the only reason I got registered in the tax system was to claim back the tax withheld on my bank account interest. Last year before they would approve the refund cheque I had to go to the local Revenue Department office and fill in a form about my pension and some other things, I can't remember what exactly now. I told them that I won't be getting my UK state pension until I reach 66 years old (true), eight years away, and that seemed to satisfy them. So it's not quite correct to say that they don't show any interest in your overseas affairs.

 

I also heard of one guy who wanted to claim back the tax withheld on his bank accounts and he rather foolishly included his UK pension in the Thai tax return. I was told that the RD said they wanted him to pay tax on this income but I never heard any more on what actually happened.

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23 hours ago, Pib said:

And everyone should not confuse the OECD-driven CRS with the U.S.-driven FATCA.   FATCA is focused on U.S. citizens/businesses; CRS is focused the citizens/businesses of countries signed up to it.  They are two different (but similar) financial reporting instruments.  

 

And I expect many countries/financial organizations will try to kill two birds with one stone by creating account questionnaires, forms, data retrievals, and reporting that satisfies both instruments. 

 

But the handwriting is clearly on the wall....it's getting harder and harder to not report financial accounts (intentionally or unintentionally) a person or business  holds in other countries.   More countries will slowly jump on this financial information exchange bandwagon from the need to collect more tax revenue and/or to avoid negative impacts from not participating.

 

 

Yes, I think you're right, that's probably why Barclays have misleadingly called this CRS form a FATCA form, to kill two birds with one stone.

 

And indeed, the handwriting is on the wall. For many years a lot of people, especially those who had spent a significant portion of their careers working overseas, a planned retirement basically meant putting as much money as possible into an offshore tax haven and then living off the tax-free income in a sunny climate. Thailand doesn't seem to be affected by this at the moment, but many expats who've retired in countries that have signed up to CRS will probably find this pretty painful.

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On 08/12/2016 at 8:50 AM, Oxx said:

 

The Thai authorities have no interest whatsoever in your offshore investments.  One doesn't include them in one's annual tax return.

The Thai authorities have no interest whatsoever in your offshore investments yet.  One doesn't include them in one's annual tax return as of now. But when the Thai authorities realise that they are missing out on a huge potential income stream things may change.

 

I personally have decided not to obtain a Thai tax number and not reclaim a few thousand baht in interest withholding tax  deductions from my bank account.

 

I just have a bad feeling how Thailand may change for the worse for us retirees.

 

 

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17 minutes ago, rak sa_ngop said:

The Thai authorities have no interest whatsoever in your offshore investments yet.  One doesn't include them in one's annual tax return as of now. But when the Thai authorities realise that they are missing out on a huge potential income stream things may change.

 

I personally have decided not to obtain a Thai tax number and not reclaim a few thousand baht in interest withholding tax  deductions from my bank account.

 

I just have a bad feeling how Thailand may change for the worse for us retirees.

 

 

 

The inordinately wealthy people who runs this country have a vested interest in not subjecting their overseas investments to tax.  Nothing's going to change.

 

Remember how a certain former Prime Minister used offshore accounts to avoid paying tax before having to flee the country as a criminal fugitive?

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I'm surprised that there's not more interest in this as several people I know have also received a demand from their offshore bank to fill in a FATCA/CRS declaration. I know Americans are already lumbered with FATCA so there's nothing new here, but all the Europeans, Canadians, Australians, etc., with offshore accounts should also be receiving similar demands from their banks.

 

Nobody seems to know quite what to do about it. If Thailand continues to show no interest in our offshore financial affairs then there's no problem with providing the TIN they want on this form. Apparently we have 30 days to comply with this demand.

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Just as crossfeed regarding FATCA filing for Americans, it's not a hard process....or what some Americans might know better as "Filing the Report of Foreign Bank and Financial Accounts (FBAR)" or a Financial Crimes Enforcement Report (FinCEN).    This report goes to the U.S. Treasury Dept and does not substitute for foreign financial account info  you may need to also report on your federal tax return to the Internal Revenue Service (IRS).   The FBAR/FinCEN report is completely separate from a person's federal  tax return. 

 

And this annual U.S. govt form is separate from any form/questionnaire a financial company such as a bank may send you requesting related info, which will probably be a one-time/in-frequent request so they have documentation on file of "due diligence" accomplished as required by FATCA.   Seems the OECD CRS goes down the same road of requiring due diligence documentation.

 

You can either complete the required form (FinCEN 114 form) online....or download the PDF version which includes buttons to automatically upload/file the completed form.   I always use the PDF version, complete it at my leisure, and then submit/upload when done.   Assuming you can complete the form, have an internet connection, and can click the Ready to File button on the form it easy it file it.   You must file online now; can't mail it in anymore. 

 

And the form hasn't changed for several years now which means you pull-up last year's form you completed, update/tweak the financial account info from last year, and click the form's submit Ready to File button again and it gets uploaded to the U.S. Treasury Dept.  

 

You immediately get a confirmation email that it's been received and a few days latter you get another email saying the form has been accepted/Uncle Sam is happy with the info you submitted (assuming he is happy with what you submitted....he has been with me so far).

 

Regardless of a person's feelings towards having to submit the foreign financial account info if exceeding more than $10K anytime during the year, the filing process is not hard at all...and you get several email confirmations of filing....no need to worry about did the form make it by snail mail (which is no longer accepted).

 

U.S. Treasury FBAR/FinCEN Filing Website 

http://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html

 

 

 

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7 hours ago, Guderian said:

I'm surprised that there's not more interest in this as several people I know have also received a demand from their offshore bank to fill in a FATCA/CRS declaration. I know Americans are already lumbered with FATCA so there's nothing new here, but all the Europeans, Canadians, Australians, etc., with offshore accounts should also be receiving similar demands from their banks.

 

Nobody seems to know quite what to do about it. If Thailand continues to show no interest in our offshore financial affairs then there's no problem with providing the TIN they want on this form. Apparently we have 30 days to comply with this demand.

Guderian I had this a few months ago from Lloyds International and there was a thread about this at the time. I have a TIN (for reclaiming tax on interest) but decided not to offer this information to the bank. I have no problem with them disclosing my info to HMRC as I am officially non resident for tax - hence my reasoning that there is no need for them to be aware of any other country tax codes or similar :smile:

 

By the time I received it I think I supposedly had a week to return it which was never going to happen. I had some fairly sharp words with my "Relationship Mgr" who admitted that he had received several similar "complaints". it was coming from a completely different office however and eventually they accepted my submission.

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12 hours ago, topt said:

Guderian I had this a few months ago from Lloyds International and there was a thread about this at the time. I have a TIN (for reclaiming tax on interest) but decided not to offer this information to the bank. I have no problem with them disclosing my info to HMRC as I am officially non resident for tax - hence my reasoning that there is no need for them to be aware of any other country tax codes or similar :smile:

 

By the time I received it I think I supposedly had a week to return it which was never going to happen. I had some fairly sharp words with my "Relationship Mgr" who admitted that he had received several similar "complaints". it was coming from a completely different office however and eventually they accepted my submission.

 

Thanks for that, it's helpful. It sounds like we're in similar boats, though Barclays seem to be some way behind Lloyds in implementing this.

 

When you told them that you didn't have a Thai TIN what was their response? I was thinking of doing the same thing but they may come back and tell you that you have to get registered in the Thai system. If not, then it's probably the best course of action. According to Oxx's posts above the Thai RD isn't interested in your overseas income, but all the same there's no point in risking your bank, or some other random organisation with access to your financial data under CRS, flagging your offshore income to the RD.

 

Did you get some useful replies on your thread, and if so would you mind pointing me to it, there doesn't seem to be much help to be found on Google at the moment. Thanks.

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17 minutes ago, Guderian said:

 

Thanks for that, it's helpful. It sounds like we're in similar boats, though Barclays seem to be some way behind Lloyds in implementing this.

 

When you told them that you didn't have a Thai TIN what was their response? I was thinking of doing the same thing but they may come back and tell you that you have to get registered in the Thai system. If not, then it's probably the best course of action. According to Oxx's posts above the Thai RD isn't interested in your overseas income, but all the same there's no point in risking your bank, or some other random organisation with access to your financial data under CRS, flagging your offshore income to the RD.

 

Did you get some useful replies on your thread, and if so would you mind pointing me to it, there doesn't seem to be much help to be found on Google at the moment. Thanks.

Fortunately I am not a prolific poster..........(and was not my thread)

I sent the form back without any such information and explained it. I then had several conversations with my relationship manager and eventually they accepted it. There is nothing they can do to force you to get one so the worst case is they report your offshore income/savings to HMRC - which in my case I don't have an issue with if they really have to. 

I don't see HMRC at the moment sending random financial info to the Thai Revenue office if there is no official Thai reference no. to match against your name.

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3 hours ago, topt said:

Fortunately I am not a prolific poster..........(and was not my thread)

I sent the form back without any such information and explained it. I then had several conversations with my relationship manager and eventually they accepted it. There is nothing they can do to force you to get one so the worst case is they report your offshore income/savings to HMRC - which in my case I don't have an issue with if they really have to. 

I don't see HMRC at the moment sending random financial info to the Thai Revenue office if there is no official Thai reference no. to match against your name.

 

Thanks.

 

One person I've talked to about this seems to think that if you refuse to fill in the form or provide the information requested they might stop providing you with banking services, basically tell you to go and find another bank. I've no idea if they can do that or not, I mean if you refuse to move what can they do, steal all your money, or at least more of it than they already do, 555? I don't see anything quite that harsh mentioned in the form from Barclays so as you say the worst they can do is probably to send your information to HMRC which is of no worry to us as non-residents.

 

One other possibility is to fill in the form but refuse to sign the authorization for them to share the information. I don;t have any problem with Barclays having this information as they already know so much about my affairs, but I don't agree with them sharing it with all and sundry. I wonder what they'd do in that case?

 

 

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3 hours ago, Guderian said:

 

Thanks.

 

One person I've talked to about this seems to think that if you refuse to fill in the form or provide the information requested they might stop providing you with banking services, basically tell you to go and find another bank. I've no idea if they can do that or not, I mean if you refuse to move what can they do, steal all your money, or at least more of it than they already do, 555? I don't see anything quite that harsh mentioned in the form from Barclays so as you say the worst they can do is probably to send your information to HMRC which is of no worry to us as non-residents.

 

One other possibility is to fill in the form but refuse to sign the authorization for them to share the information. I don;t have any problem with Barclays having this information as they already know so much about my affairs, but I don't agree with them sharing it with all and sundry. I wonder what they'd do in that case?

 

 

Of course any bank can close your account and refuse you services for any reason or no reason. Newspapers are full of stories about this happening all the time. Barclays is one of the banks that does this routinely, and they do not have to offer any explanation or compensation. (Some links below to Barclays and HSBC as examples)

 

That is the worry about these forms if you need your bank account to stay open to be able to function financially.

 

The way that the FATCA/CRS system functions is that banks are not allowed to share information about accounts that you may have, but the legally binding agreements that 100 or so governments for CRS and the US for FATCA have entered into means that any UK banks that know that they have accounts held by residents of another state that is in the agreement (reportable accounts) MUST give the information to HMRC.  HMRC is the legal entity that is allowed to (and obliged to) give this information to the member state concerned .

 

There is no need to worry at all about Thailand TIN numbers - Thailand is not a member state in this agreement, and isn't  likely to be soon, so an account in Thailand is not a reportable account and this information will not go to HMRC. No information can ever be sent to Thailand by HMRC therefore.

 

http://www.thisismoney.co.uk/money/news/article-3169957/Barclays-shuts-accounts-expats-living-Cyprus-Malta-unless-hold-100-000-more.html

 

https://www.theguardian.com/money/2015/oct/03/hsbc-derisking-account-frozen-marie-shaun-langley

 

https://www.theguardian.com/money/2015/aug/26/hsbc-closed-bank-accounts

Edited by partington
corrected number of countries in information sharing agreement
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17 hours ago, partington said:

Of course any bank can close your account and refuse you services for any reason or no reason. Newspapers are full of stories about this happening all the time. Barclays is one of the banks that does this routinely, and they do not have to offer any explanation or compensation. (Some links below to Barclays and HSBC as examples)

 

That is the worry about these forms if you need your bank account to stay open to be able to function financially.

 

The way that the FATCA/CRS system functions is that banks are not allowed to share information about accounts that you may have, but the legally binding agreements that 100 or so governments for CRS and the US for FATCA have entered into means that any UK banks that know that they have accounts held by residents of another state that is in the agreement (reportable accounts) MUST give the information to HMRC.  HMRC is the legal entity that is allowed to (and obliged to) give this information to the member state concerned .

 

There is no need to worry at all about Thailand TIN numbers - Thailand is not a member state in this agreement, and isn't  likely to be soon, so an account in Thailand is not a reportable account and this information will not go to HMRC. No information can ever be sent to Thailand by HMRC therefore.

 

http://www.thisismoney.co.uk/money/news/article-3169957/Barclays-shuts-accounts-expats-living-Cyprus-Malta-unless-hold-100-000-more.html

 

https://www.theguardian.com/money/2015/oct/03/hsbc-derisking-account-frozen-marie-shaun-langley

 

https://www.theguardian.com/money/2015/aug/26/hsbc-closed-bank-accounts

 

Thank for that.

 

I'm currently inclining towards topt's approach (post #22 above) and thinking of sending the form back with no Thai TIN but an explanation that under the Thai RD's definitions I've never had any taxable income here in Thailand so it's never been necessary to become a formal part of the Thai tax system.

 

Any thoughts on this?

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20 hours ago, Guderian said:

I mean if you refuse to move what can they do, steal all your money, or at least more of it than they already do, 555?

 

They don't steal your money, they simply put a block on the account, preventing your accessing it until you've satisfied their requirements.

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3 hours ago, Guderian said:

 

Thank for that.

 

I'm currently inclining towards topt's approach (post #22 above) and thinking of sending the form back with no Thai TIN but an explanation that under the Thai RD's definitions I've never had any taxable income here in Thailand so it's never been necessary to become a formal part of the Thai tax system.

 

Any thoughts on this?

It depends on what you are concerned about. As there is no agreement or mechanism in place for HMRC to share information with the Thai RD or vice versa, I can't see any disadvantage in giving your Thai TIN number.

 

The point is not that HMRC want to find out if you are taxable in the UK, but that HMRC are the agency through which all information exchange must take place, therefore your bank determines whether to send your information to HMRC, on the basis of you having a reportable account. 

 

You don't so they won't.

 

However the point as far as the bank is concerned is that they save money by limiting the number of times they need to check everyone's tax residency. So they ask about tax residency in ANY country, whether it counts as a "reportable country" or not. That way if Thailand signs up to this agreement in 5 years time they have the information already.  

 

I don't care about this at all. I care about the possibility of my bank closing or freezing an account that is currently essential to me on the basis of me not being compliant with their FATCA/CRS requests.

 

 

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