Pre-existing individual accounts Overview In broad terms, a pre-existing individual account is an account that is both: maintained by a Reporting NZFI as of 30 June 2017; and held by an individual. An additional account opened by a pre-existing customer on or after 1 July 2017 is also treated as a pre-existing account in the following circumstances: the account holder holds with the Reporting NZFI (or a related entity in New Zealand) a financial account that is a pre-existing account; the Reporting NZFI (and any related entity) treats both accounts as a single account for the purposes of satisfying the of knowledge” requirements and determining the “standards balance or value of the account when applying any account thresholds; if the financial account is subject to AML/KYC procedures, the Reporting NZFI is permitted to satisfy such procedures for the financial account by relying on the AML/KYC procedures performed for the pre-existing account; and opening the financial account does not require the account holder to provide new, additional or amended customer information other than for the purposes of the CRS. A Reporting NZFI is generally required to out due diligence on all pre-existing individual financial accounts to determine whether they are held by relevant foreign tax residents. There is no de minimis threshold (compared with FATCA, which has various de minimis thresholds). However, a Reporting NZFI is not required to review a pre-existing individual account that is a cash insurance contract or annuity contract if they are effectively prohibited by law from selling the contract to relevant foreign tax residents. The type of due diligence procedures that the Reporting NZFI will need to carry out on pre-existing individual accounts will depend on whether: the account is a value-account: With a balance or value of USD 1,000,000 or less (which a Reporting NZFI can simply treat as NZD 1,000,000) as of 30 June 2017; or
Pre-existing individual accounts Overview In broad terms, a pre-existing individual account is an account that is both: maintained by a Reporting NZFI as of 30 June 2017; and held by an individual. An additional account opened by a pre-existing customer on or after 1 July 2017 is also treated as a pre-existing account in the following circumstances: the account holder holds with the Reporting NZFI (or a related entity in New Zealand) a financial account that is a pre-existing account; the Reporting NZFI (and any related entity) treats both accounts as a single account for the purposes of satisfying the “standards of knowledge” requirements and determining the balance or value of the account when applying any account thresholds; if the financial account is subject to AML/KYC procedures, the Reporting NZFI is permitted to satisfy such procedures for the financial account by relying on the AML/KYC procedures performed for the pre-existing account; and opening the financial account does not require the account holder to provide new, additional or amended customer information other than for the purposes of the CRS. A Reporting NZFI is generally required to out due diligence on all pre-existing individual financial accounts to determine whether they are held by relevant foreign tax residents. There is no de minimis threshold (compared with FATCA, which has various de minimis thresholds). However, a Reporting NZFI is not required to review a pre-existing individual account that is a cash insurance contract or annuity contract if they are effectively prohibited by law from selling the contract to relevant foreign tax residents. The type of due diligence procedures that the Reporting NZFI will need to carry out on pre-existing individual accounts will depend on whether: the account is a value-account: With a balance or value of USD 1,000,000 or less (which a Reporting NZFI can simply treat as NZD 1,000,000) as of 30 June 2017; or
2016-other-aeoi-guidance-draft.docx