ARNO/ RNOC has put together some briefing notes on the Common Reporting Standard:
Under a global agreement for exchange of information and an EU Directive on Administrative Cooperation known as the Common Reporting Standard (CRS), any charity which receives 50% or more of its gross income from investments and has any part of those assets under management via a discretionary investment mandate, falls within the definition of a “Financial Institution” and is therefore required to obtain data and potentially report on “Account Holders”.
A Financial Institution that is legally formed as a charitable trust will have to regard its charitable grantees as well as any living settlor as “Account Holders”, since these will be seen under the CRS as having an “equity interest” in the charity. This means that due diligence will need to be undertaken on all beneficiaries of those charitable trusts. Essentially this means determining whether or not a beneficiary is resident in the UK for tax purposes, and if not, beneficiaries should be asked to self-certify their tax residence and to provide a tax identification number if possible.