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Account Holder flow chart

Eight steps to work out if you as a financial institution can determine if you have any financial accounts.

Last updated 6 June 2018

A Financial Institution is required to determine if it has any Financial Accounts. Financial Accounts for CRS purposes has a special meaning. Under the CRS Financial Accounts are debt and equity interests in the NFP. Financial Accounts are held by Account Holders. The structure of your NFP will have an impact on who your Account Holders are. Each time you determine you have an Account Holder, record that information as you may have to report the Financial Account to us at the end of the reporting period.

Note:

1. When an account is held jointly, each joint holder is treated as an Account Holder.

2. You do not need to start determining your Account Holders until 1 July 2017, as the first reporting period is 1 July 2017 to 31 December 2017. In some situations you will not be able to determine your Account Holders until the end of the period.

Use this worksheet to help you determine if an individual or entity has a debt or equity interest in your NFP.

Step 1 – Debt interests

Does your NFP have any loans or any other borrowing arrangements?

Note: The entities and individuals you have loan and borrowing arrangements with have debt interests and are Account Holders for the purposes of the CRS.

Yes

Record these Account Holders for your future reference and continue on to determine if you have any other Account Holders.

Go to Step 2.

No

You do not currently have any Account Holders with debt interests.

Go to Step 2.

Step 2 – Equity interests

Is your NFP a corporation (company or an incorporated organisation)?

Yes

Go to Step 3

No

Go to Step 4

Step 3 – Shareholders

Does your NFP have any shareholders?

Note: Shareholders have equity interests and are Account Holders for the purposes of the CRS.

Yes

Record these Account Holders for future reference and continue on to determine if you have any other Account Holders.

Go to Step 5

No

Go to Step 5

Step 4 – Trust or other similar legal arrangement

Is your NFP a trust or other similar legal arrangement that holds property on trust?

Note: Other similar legal arrangements include unincorporated associations.

Property includes money and shares.

Yes

Go to Step 6

No

You do not currently have any Account Holders with equity interests. Go back to Step 2 of the Common Reporting Standard flow chart.

Step 5 – Holding property on trust

Does your NFP hold property in trust separately from its corporate assets?

Note: This includes money and shares.

Yes

Go to Step 6

No

You do not currently have any Account Holders with equity interests. Go back to Step 2 of the Common Reporting Standard flow chart.

Step 6 – Settlors

Does the trust have any settlors?

Note: Settlors have equity interests and are Account Holders for the purposes of the CRS.

Yes

Record these Account Holders and continue on to determine if you have any other Account Holders.

Go to Step 7

No

Go to Step 7

Step 7 – Beneficiaries

Does the trust have any beneficiaries?

Note: Beneficiaries include grant recipients, discretionary beneficiaries that received grants or distributions in the reporting year, and fixed beneficiaries. Exclude payments made for goods and services.

Normally, the individual or entity (Entity A) that you pass the grant to will be the Account Holder.

However, if you pay a grant to Entity A and they hold it for the benefit of another individual or entity (Entity B) and Entity A does not have the discretion on how and when it is spent, the Account Holder is Entity B.

If you do not know how the grant will be spent or who it will go to, then you may treat Entity A as the Account Holder.

Beneficiaries have equity interests and are Account Holders for the purposes of the CRS.

Yes

Record these Account Holders for your future reference and continue on to determine if you have any other Account Holders.

Go to Step 8

No

Go to Step 8

Step 8 – Ultimate effective control

Are there any natural persons that exercise ultimate effective control over the trust?

Note: This includes trustees, and in the case of a corporate trustee any director with control of the corporate trustee, and any controlling beneficiaries.

Natural persons that exercise effective control over the trust have equity interests and are Account Holders for the purposes of the CRS.

Yes

Record these Account Holders for your future reference and go back to Step 2 of the Common Reporting Standard flow chart.

No

Go back to Step 2 of the Common Reporting Standard flow chart.

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