Common Reporting Standard and Compliance Obligations for Nigerian Financial Institutions

The first set of Common Reporting Standard (CRS) reports are due for filing with the Federal Inland Revenue Service (FIRS) on Wednesday, 30 September 2020. This is following a four (4) month extension of the initial filing deadline from 31 May 2020. The extension was part of the palliative measures put in place by FIRS to ease the tax compliance burden of Reporting Financial Institutions (RFIs), in response to the disruption caused by the COVID-19 pandemic. RFIs are defined as depository Institutions (e.g. savings banks, commercial banks, savings and loan associations
and credit unions), custodial Institutions (e.g. custodian banks and stockbrokers), investment entities (e.g. portfolio and asset management companies) and specified insurance companies (e.g. life insurance companies).

The CRS, an initiative of G20 countries was developed and approved by OECD on 15 July 2014. It is a standard for Automatic Exchange of Information (AEOI), at a global level, between competent authorities of different participating jurisdictions. The legal basis for CRS includes Article 6 of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (“the Convention”), CRS Multilateral Competent Authority Agreement for AEOI (“CRS MCAA”) and domestic legislation of participating jurisdictions. As at 3 September 2020,about 109 jurisdictions, including Nigeria, have signed the CRS MCAA.

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