FATCA/CRS, governance and oversight: how to be prepared to tax authorities controls?

Since January 2021, all Luxembourg Financial Institutions ("FIs") must establish a FATCA/CRS compliance programme, encompassing various requirements such as IT infrastructure, written policies and procedures, and oversight in case of delegated functions. A second crucial pillar of this compliance programme requires FIs to implement proportionate and effective controls to ensure compliance with FATCA and CRS due diligence and reporting obligations.

This training encompasses all essential FATCA and CRS key principles, illustrated with concrete examples, along with best-market practices to establish an efficient FATCA/CRS operating model and mitigate challenges faced by financial institutions (FIs).

Additionally, the training offers insights into recent regulatory updates (if any) and outlines the controls and inquiries conducted by the Luxembourg tax authorities.

By the end of this training, participants will be able to:

• determine which procedures should be put in place or amended;
• upgrade their client/investor onboarding process;
• assess whether they receive sufficient information and comfort from their service providers.

• Best practices in terms of procedures
• Areas of risk
• Common mistakes in client due diligence and reporting
• Documentation of the implemented controls
• Oversight - what are the key points to control in case of delegation

This training will be coordinated by Pierre Kirsch, Partner at PwC Luxembourg.

Pierre, Tax Partner, is an authorised manager of the PFS Tax Information Reporting department where he is in charge of all services around tax transparency and automatic exchange of information.

He has spent more than 27 years working for clients in the private banking and asset management industries in Luxembourg where he has acquired a deep knowledge of their internal processes.

Pierre has performed different tax transparency analyses of the private and corporate client base of several major financial institutions in Luxembourg and abroad, with the objectives to determine the level of risk of non-tax-compliant clients and define an appropriate and measurable action plan.