Common Reporting Standard (CRS)

Frequently Asked Questions for CRS for Clients

1. What is Common Reporting Standard (“CRS”)?

The CRS for Automatic Exchange of Information (“AEOI”), endorsed by OECD (Organization for Economic Cooperation and Development) refers to the automatic exchange of financial account information between jurisdictions for tax purposes, with the objective of detecting and deterring tax evasion by taxpayers through the use of offshore financial accounts. It typically pertains to information relating to accounts maintained by taxpayers in Financial Institutions (FIs) located in a jurisdiction outside of their own.

Under CRS, financial account information includes insurance policy information. Financial Institutions including Aviva Ltd (“Aviva”), are required to perform customer due diligence procedures and report the insurance policy information to the Inland Revenue Authority of Singapore (“IRAS”).
 

2. Who is considered as a Reportable Person?

The following persons who are tax residents of jurisdictions other than Singapore are considered as Reportable Person:

  1. A policyholder who is an individual or corporate entity*, holding a policy with cash value or premium refund feature which is paid by cash or Supplementary Retirement Scheme (“SRS”);
  2. A beneficial owner of a policy contract;
  3. A settlor, trustee and nominated beneficiary of a policy contract under or subject to a trust;
  4. An assignee(s) of a policy contract;
  5. A claimant;
  6. An individual who exercises control over a corporate entity (typically on the basis that he/she holds at least 25% shareholding in the corporate entity) – “Controlling Person”;
  7. Any person entitled to access the cash value or change the beneficiary of the policy contract.

* A corporate entity for CRS purposes include:

  1. An FI such as a Depository Institution, Custodian Institution, Bank or insurance company;
  2. An FI other than an investment entity e.g. a Fund manager;
  3. An FI, which is an Investment Entity in a non-participating jurisdiction and managed by another FI, e.g. US Fund managed by another FI;
  4. An Active NFE (“Non-Financial Entity”) such as a manufacturing factory;
  5. A Passive NFE such as a holding company;

Note: A Government entity and a Central bank are non–reportable entities.
 

3. How does the CRS implementation impact me?

With effect from 1 Jan 2017, the Application forms# will contain relevant CRS questions to be answered. Please ensure that:

  1. The CRS questions are answered; and
  2. The relevant Self–Certification Forms to be completed^.

We have made changes to Policy Servicing and Claim forms# incorporating CRS declaration with effect from 1 Aug 2017.

# CRS Related Documents (collectively called “Aviva Forms”):

  1. New Business Application Forms
    • Insurance Investment Application Form
    • Guaranteed Issuance Application Form
    • Simplified Issuance Application Form
  2. Policy Servicing and Claims forms
    • Nomination of Beneficiary Form
    • Assignment Form
    • All payout related forms such as Surrender/Withdrawal Form, Bonus Surrender Form
    • Change of Personal Details Form
    • Change of address and contact details Form
    • Application for Reinstatement of Lapsed Policy Form
    • Claim Form – Critical Illness &/or Male/Female/Child Illness Claim
    • Claim Form – Death Claim
    • Claim Form – Disability and/or Terminal Illness Claim
    • Claim Form – Personal Accident Claim
    • Claim Form – Benefit Claim
    • Claim Form – Retail & Individual Medical Claim
       

    ^ CRS Self Certification Forms:

    • CRS Self Certification for Individual
    • CRS Self Certification for Entity
    • CRS Self Certification for Controlling Person
       

4. Why am I receiving this letter?

Aviva is carrying out a one-time mailing exercise to all existing clients/policyholders, who fall within the scope of the CRS, to request them to complete and submit the CRS Self Certification forms. As you’ve one or more foreign indicia, you’re therefore required to complete the CRS Self Certification Form to confirm your tax residency status and return to us within one month.

If you’ve a corporate entity, you’re required to complete the "CRS Self Certification Form for Entity" where you need to self-certify on behalf of an Entity (which includes businesses, professionally managed trusts and partnerships). Similarly, if you’re a Controlling Person of an Entity, please complete the "CRS Self Certification for Controlling Person". You can find these forms at www.aviva.com.sg/CRS.

Do note that if you don’t respond to our request to confirm your tax residency status, we’ll have to treat you as tax residents in the respective foreign jurisdictions, based on the information available in our records.
 

5. Who needs to complete the CRS Self Certification Form?

Every Account Holder should complete the CRS Self Certification Form. For joint Account Holders, each individual will need to complete the form.

For the purpose of this Self Certification, an Account Holder may refer to the following person: Proposer (eventually the Policyowner), Sole Trader, Sole Proprietor, Controlling Person, Beneficial Owner, Assignee, Trustee, Settlor, Beneficiary under a Trust or a Trust Nominee named under section 49L of the Singapore Insurance Act (Chapter 142) or Proper Claimant as defined under section 61 of the Singapore Insurance Act (Chapter 142).

If you’ve provided information in relation to the United States Government Foreign Account Tax Compliance Act (“FATCA”), you’re still required to provide additional information for the CRS as this is a separate regulation.
  

6. What would constitute a “change of circumstances”?

A “change of circumstances” includes any change that results in the addition of information relevant to a person’s status, which includes any change or addition of information to the Account Holder’s account/any account associated with such account, if such change or addition of information affects the status of the Account Holder.

 

7. Do I need to notify Aviva in the event of change in my country of tax residency?

You should inform us of any change in circumstances, such as long-term job postings to a foreign jurisdiction, which may affect your tax residency status. It’s important to ensure that all submissions to us are accurate.

 

8. How can I notify Aviva if there is a change in my country of tax residency?

You’ll have to complete and submit the “Change of Personal Details Form” together with the CRS Self Certification Form.

 

9. Will my servicing request be put on hold if these documents are outstanding?

No, the processing of the relevant transactions will not be delayed if the CRS Self Certification forms are not received. However, if we don’t receive the CRS Self Certification Form after 90 days from the date of this letter, we’ll have to treat you as tax resident in the respective foreign jurisdiction based on the information available in our records for reporting to IRAS.

 

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