Impact of CRS on processes

The introduction of CRS has resulted in some process changes.

To which life assurance products does CRS apply?     

CRS applies to savings, investments and unit linked protection products when the plan is owned by an individual or entity that is resident, for tax purposes, anywhere other than the Republic of Ireland (ROI) or the USA. To establish whether CRS applies at new business stage, a question will be included on all application forms and on ePOS. 

Changes to the application form – individuals 

From 1st January 2016, Irish Life application forms and ePOS will have new questions relating to CRS. Individuals will be asked to certify their country of birth, country of residence for tax purposes and for their Tax Identification Number (TIN) if tax-resident outside of the ROI or the USA. It is possible to be tax-resident in more than one country and it may be the case that an individual or entity is tax-resident in the ROI and/or the USA as well as other countries. 

As Irish Life’s products are not licensed to be sold or marketed outside of the ROI, it cannot accept any new business application if the policy owner (proposer) is not habitually and tax resident in the ROI. Therefore there will be very limited circumstances when CRS applies to Irish Life policies; potentially those written in trust or assigned or when dual tax-residency applies. 

Changes to the application form – entities 

If the policy owner is an entity, the entity will be asked to certify: 

  • The entity’s country of incorporation and country of tax residency  
  • The names of those controlling the entity (25%+ shareholding or voting rights), their country of residence and Tax Identification Number 
  • The entity must be recorded as a third party authority

Financial institutions, government bodies and companies trading on a recognised stock exchange are exempt.  
From 1st January 2016, Irish Life application forms and ePOS will have new questions to record this information.   

N.B. As Irish Life products are not licensed to be sold or marketed outside of the ROI, it cannot accept any 
new business where the policy owner (proposer) is not habitually resident and tax resident in the ROI. Therefore, there will be very limited circumstances when CRS applies to Irish Life policies; potentially those 
written in trust or assigned or when dual tax-residency applies.

Requirements for policies written in trust 

Trusts are treated in the same way as an entity.  If a policy is to be written in trust, the following must be established for all interested parties (trustees, settlor, plan owner, known beneficiaries).   

  • Country of residence  
  • Tax Identification Number (TIN) - if tax-resident outside of the Republic of Ireland or the USA   

It is possible to be tax-resident in more than one country and it may be the case that an individual or entity is tax-resident in the ROI and/or the USA as well as other countries. 

From 1st January 2016, Irish Life application forms will have new questions to capture this. ePOS does not currently have a field for capturing all interested parties so the new business team will liaise with the financial adviser to get this information. 

N.B. As Irish Life’s products are not licensed to be sold or marketed outside of the ROI, it cannot accept new business if the policy-owner (proposer) is not habitually resident and tax resident in the ROI. Therefore, there will be very limited circumstances when CRS applies to Irish Life policies; potentially those written in trust or assigned or when dual tax-residency applies. 

Requirements for existing policies being assigned 

If an existing policy is being assigned, we must establish the country of residence of the new policy owner. Depending on whether the new policy owner is an individual or an entity, the applicable new business requirements will apply.  

Data protection

The customer will be informed via ePOS tooltips and on the application’s declaration, of why the data is being collected, how it will be used, what will be reported to Revenue, that it may be exchanged with other tax authorities (by Revenue) and details of where the customer can get further information.