The British Virgin Islands International Tax Authority has launched its BVI Financial Account Reporting System.

The portal was opened yesterday and is ready to accept enrolment applications from BVI reporting financial institutions (FIs) which are required to submit information under the inter-governmental agreement between the BVI and the United States.

BVI reporting financial institutions and sponsoring entities are required to enrol with the reporting system prior to submitting FATCA information to the tax authority. The deadline to register in order to submit information in the 2015 reporting cycle is 1st June. Enrolment is a one-off exercise but is subject to review and approval by the tax authority – nobody knows exactly how long the process will take, so it is unwise to leave enrolment until close to the deadline. As previously announced, the reporting deadline for the 2014 period is 30 June 2015 with the deadline in subsequent years (2016 onwards) being 31 May.
 
Once the application for enrolment is approved, a financial institution profile is created and the BVI reporting FI will be given an automated unique identification number. Each BVI reporting FI will have a 'primary user' who will be able to appoint up to three additional 'secondary users.'

FIs are required to submit their registered names, institution types and GIINs [Global Intermediary Identification Numbers] as part of the enrolment process. Although that enrolment process is conducted entirely online, each primary user is required to upload a scanned copy of his passport and a letter signed by a director of the FI specifying that he is the person responsible for US FATCA compliance.
 
It is important to note that the tax authority does not require FIs to submit NIL reports, i.e. reports that are generated and submitted without any information pertaining to the account reports or pooled reports. The ITA does not require FIs to enrol with the reporting system if they have nothing to report, but the reporting system will accept a NIL report if a financial institution wishes to submit one. Equally, a financial institution with nothing to report may enrol and not submit a NIL report.

The Government has also produced a user guide for the reporting system. It is available at http://bvi.gov.vg/sites/default/files/bvi_fatca_-_bvifars_user_guide_-_clean_v_3_-_15-4-15.pdf