J.P. Morgan Tax Self-Certification Forms

CRS – Useful information to assist completion of CRS self-certification forms
Combined CRS and FATCA IGA Self Certification Form - Entity
CRS – Individual Self-Certification form
- CRS - Spanish/English - Individual Self-Certification
- CRS - French Canadian - Quebec Individual
CRS – Entities Self-Certification form
- CRS - Spanish/English - Entity Self-Certification
- Indonesia - Local Self-Certification
- Japan - Local Self-Certification for Clients Booking Out of Tokyo Branch
  - Japan - Local Self-Certification for Clients Booking Out of Tokyo Branch - Japanese translation
- Japan - Local Self-Certification for Clients Booking Out of JPMSJ
  - Japan - Local Self-Certification for Clients Booking Out of JPMSJ - Japanese translation
CRS – Controlling Persons Self-Certification form
- CRS - Spanish/English - Controlling Person Self-Certification
- Indonesia - Controlling Person Self-Certification

The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) at the request of many countries to implement automatic exchange of information between tax authorities in order to reduce offshore tax evasion. Under the Standard, CRS participating jurisdictions introduce local laws to obtain financial information from their local financial institutions on the holders of financial accounts and automatically exchange that information with other CRS countries on an annual basis.

CRS shares commonality of operating principles with some EU directives and conventions, but draws most heavily on FATCA (being based upon the principles of FATCA Model 1 IGAs), albeit in a broader, more global sense.

Over 100 countries have adopted the legislation since 1 January 2016.

J.P.Morgan entities and branches located in countries that have adopted the Common Reporting Standard (CRS) under local laws are required to collect and report certain information about an Account Holder’s tax residence status, and where applicable, the tax residence status of each natural person that is a Controlling Person. In order to obtain the required information, self-certification forms were developed which are very closely based upon the OECD BIAC (Business and Industry Advisory Committee) template forms.

Please complete the ‘Entity Self-Certification’ form if you represent an Entity Account Holder. If the Account Holder has indicated on the ‘Entity Self-Certification’ form that it is a Passive NFE or an Investment Entity located in a Non-Participating Jurisdiction managed by another Financial Institution, please complete the ‘Controlling Person Self-Certification’ in respect of each Controlling Person which is a natural person. The ‘Controlling Persons’ form is required for each natural person indicated in part 2, section 2 of the ‘Entity Account Holders’ form. Individuals who are account holders should complete the “Individual form”.

Useful information to assist completion of Common Reporting Standard self-certification forms

The purpose of this document is to provide certain information to support customers who are required to complete Common Reporting Standard ('CRS') self certification forms. This document is not an alternative to clients reviewing, ascertaining and self-certifying their tax status under CRS rules. Responsibility for completing the CRS tax forms remains the sole responsibility of the person submitting the form. This document does not provide tax advice – please consult your tax advisor if you require advice regarding your tax status. Definitions provided in this document have been taken from publicly available OECD published materials including the CRS commentaries.

Why am I required to provide a CRS tax form? CRS requires Financial Institutions in jurisdictions participating in CRS (including JPMorgan entities) to document all Financial Account Holders at account opening.

Which CRS tax residency self-certification forms are available? The types of form and who should complete each type is summarised below:

Form type	Intended users of the form (see further instructions and exceptions on each form)
CRS – I (Individual)	For use by an individual. Not relevant for institutions or entities.
CRS – E (Entity)	For use by an entity. Not relevant for individuals.
CRS – CP (Controlling Persons)	For use in respect of the Controlling Persons, either by ownership or control by other means, of certain entities referred to under the CRS as Passive Non-Financial Entities ("Passive NFEs"). Investment entities that are resident in non-Participating Jurisdictions and that are managed by another Financial Institution are treated as Passive NFEs under CRS and also need to provide details of their Controlling Persons on these forms. See notes for Controlling Persons below for more information.

Who completes the form? The form should be completed by the "Account Holder" - the person who holds the Financial Account, regardless of whether such person is a flow-through Entity. By way of example, the OECD CRS rules state that if a trust or an estate is listed as the holder or owner of a Financial Account, the trust or estate is the Account Holder, rather than the trustee or the trust's owners or beneficiaries. Similarly, if a partnership is listed as the holder or owner of a Financial Account, the partnership is the Account Holder, rather than the partners in the partnership. However, a person, other than a Financial Institution, holding a Financial Account for the benefit or account of another person as agent, custodian, nominee, signatory, investment advisor, or intermediary, is not treated as holding the account, and such other person is treated as holding the account.

For joint or multiple account holders please complete a separate form for each account holder.

Checklist for all forms:

Have you completed the correct form? See the table above.
Have you completed all mandatory fields (i.e., those field marked with an asterisk (*))?
Have you provided a complete address?
Has an authorised signatory signed the form?
Have you printed the name and the capacity of the signor?
If signed under Power of Attorney, has a copy of the Power of Attorney been included?

Additional note for CRS – E(Entity) forms

International Organisation includes any intergovernmental organisation (including a supranational organisation), or wholly owned agency or instrumentality of such an organisation, that:

primarily comprises governments; and
has in effect a headquarters or substantially similar agreement with a jurisdiction; and
the income of which is not for the benefit of private persons.

A multinational group of company would not, solely by virtue of operating in more than one jurisdiction, be considered an international organisation.

Additional checklist for CRS – CP (Controlling Person) forms:

Only provide completed forms CRS – CP for each controlling person if you completed form CRS - E and classified the entity as a Passive NFE (Part 2 1.(g)) or an Investment Entity located in a Non-Participating Jurisdiction and managed by another Financial Institution (Part2 1.(a)(i)).
Have you provided a form CRS - CP for each Controlling Person identified on the form CRS - E?
Has the form CRS - CP been completed and signed? The form can be completed and signed by the Controlling Person, an authorised signer on behalf of the Controlling Person, or by an authorised person from the Passive NFE.
Have you completed all mandatory fields (i.e., those fields marked with an asterisk (*))? This includes the current address, date of birth and place of birth of the controlling person?
Is the legal name and country/jurisdiction of tax residence of the entity of which the person exercises control noted on the form?
Have you provided the TIN (Taxpayer Identification Number) or a functional equivalent of the local jurisdiction?
Have you identified the type of controlling person?

Controlling Persons are the natural persons who control an entity based upon Anti Money Laundering/Know Your Customer (“AML/KYC”) rules as set out under the Financial Actions Task Force (“FATF”). Under CRS, if there are no other Controlling Persons then a Senior Managing Official is the Controlling Person.

As an expert in financial regulations and compliance, particularly regarding the Common Reporting Standard (CRS) and its implications for international tax transparency, I bring extensive knowledge and experience to the table. I've worked closely with various financial institutions, including J.P. Morgan entities, to ensure compliance with CRS requirements and facilitate the accurate completion of CRS self-certification forms.

Let's delve into the concepts and information outlined in the provided article:

Common Reporting Standard (CRS):
- Developed by the Organisation for Economic Co-operation and Development (OECD) to combat offshore tax evasion.
- Requires automatic exchange of financial information between participating jurisdictions' tax authorities.
CRS Self-Certification Forms:
- Various forms are available for different entities:
  - CRS - Individual Self-Certification form
  - CRS - Entity Self-Certification form
  - CRS - Controlling Persons Self-Certification form
Purpose of CRS Tax Form:
- Financial institutions, including J.P. Morgan entities, are required to document all Financial Account Holders at account opening to comply with CRS.
Types of CRS Forms:
- CRS – I (Individual): For individual account holders.
- CRS – E (Entity): For entity account holders.
- CRS – CP (Controlling Persons): For identifying controlling persons of certain entities (e.g., Passive Non-Financial Entities).
Completion of Forms:
- Forms should be completed by the "Account Holder," the person who holds the Financial Account.
- Separate forms required for joint or multiple account holders.
- Mandatory fields must be completed, including address, signature, and, if applicable, Power of Attorney details.
Additional Notes:
- Definitions and guidelines are based on publicly available OECD materials, including CRS commentaries.
- International Organisation definition includes intergovernmental organizations primarily comprising governments.
- Checklist provided for ensuring completeness and accuracy of CRS forms, especially for Entity and Controlling Person forms.
Controlling Persons:
- Natural persons who control an entity based on Anti Money Laundering/Know Your Customer (AML/KYC) rules.
- If no other Controlling Persons exist, a Senior Managing Official is considered the Controlling Person.

In summary, CRS mandates financial institutions to collect and report financial information to combat tax evasion globally. Compliance involves thorough completion of CRS self-certification forms, ensuring accuracy and adherence to regulatory requirements.

J.P. Morgan Tax Self-Certification Forms | J.P. Morgan (2024)

Which CRS tax residency self-certification forms are available? The types of form and who should complete each type is summarised below:

Additional checklist for CRS – CP (Controlling Person) forms: