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 Kirsch is a partner in the Luxembourg financial services tax practice with over 29 years of experience serving clients in banking, insurance, and asset management. He leads a team specialising in tax compliance analysis for onboarding banking clients and investors into complex alternative fund structures. Pierre and his team advise financial sector actors in Luxembourg and internationally, helping clients review onboarding and tax reporting processes, implement controls, and define organisational roles. He contributed to establishing PwC Regulated Solutions S.à r.l., managing daily operations, and supports PwC’s financial services clients with consulting and reporting on operational taxes including FATCA, CRS, QI, and CbCR.